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©Gamma Secure Systems Limited, W m List & Co., 2006 Information Security Management ISO/IEC 27001 and Internal Control Dr. David Brewer Mr. William List, CA, hon FBCS

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Page 1: Information Security Management ISO/IEC 27001 Security Management ISO/IEC 27001 ... The ISMS Standards ISO/IEC 27001 is a management ... Introduced measurement

©Gamma Secure Systems Limited, Wm List & Co., 2006

Information Security Management

ISO/IEC 27001 and Internal Control

Dr. David Brewer

Mr. William List, CA, hon FBCS

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Themes

■ Information Security Management Systems (ISMS)

■ BS 7799-2 migration to ISO/IEC 27001

■ Internal control, COSO Audit, Risk Management, SOX, Basel etc

■ Integrated management systems

■ How it can be done in practice

“What if it doesn’t work”

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©Gamma Secure Systems Limited, Wm List & Co., 2006

Agenda

■ Introduction to Information Security Management Standards

■ Relation with other standards, laws and regulations

■ Methodology

■ Commercial application

■ Case study

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ISMSSTANDARDS

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The ISMS Standards■ ISO/IEC 27001 is a management

standard – e.g. let’s party. Ittells you what to do

■ ISO/IEC 17799 is a super-market of good things to do

■ Certification, performed by an accredited certification body in accordance with EA7/03, is against 27001– is the party OK?

Effective Security in tune with

the business

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International standardisation

■ BS 7799-2:2002

■ ISO/IEC 17799:2005

■ Annex B of BS 7799-2

■ Current work on metrics

■ EA7/03

ISO/IEC 27001:2005

ISO/IEC 27002:2007

ISO/IEC 27003

ISO/IEC 27004

ISO/IEC 2700?

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ISO/IEC 27001Information Security Management Systems - Requirements

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ISO/IEC 27001

Scope •Policy •

Risk Assessment (RA) •Risk Treatment Plan (RTP) •

Statement of Applicability (SOA) •Operate Controls •

Awareness Training •

Prompt Detection and Response to Incidents •Manage Resources • •Internal ISMS Audit

•Management Review

•Corrective Action

•Preventive Action

•ISMS Improvements

This is the Deming cycle

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©Gamma Secure Systems Limited, Wm List & Co., 2006

Risk Treatment Plans

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ISMS Requirement - 1

There are different methodologies for risk assessment

assets

threats

vulnerabilitiesimpacts

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ISMS Requirement - 2

Treat the risk

Select the controls

What is the risk?

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©Gamma Secure Systems Limited, Wm List & Co., 2006

Basic Proposition

Threat

AdverseImpact

Vulnerability

Asset

Exploits

Violates

Causes

Event

What is the risk?

What shall we do?

Accept the risk

Transfer the risk

Mitigate the risk

Select the controls

Treat the risk

Avoid the risk

Choose the appropriate controls

■ Proportionality controls should be commensurate with the risk

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Not New“… a process, effected by an entity's board of directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risks to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives.”

Source: COSO Enterprise Risk Management – Integrated Framework. 2004. COSO.

Slide created by the Institute of Internal Auditors

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A Choice of Approach ■ Thousands of calculations

Asset * Threat * Vulnerability

Some methods simplify this with tables

But if asset = 0, risk = 0Asset value depends on

event and impact

■ Does the Board understand the results?

■ Don’t forget to select the controls

Why not start with these?

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Statement of Applicability

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Statement of Applicability (SOA)

Policy statements(could be imposed by higher authority)

Risk assessmentrisk treatment plan

Link backs

Link forward to procedure manuals etc.

normative

informative

A.x.x.x Clause

A.x.x.y Clause N/A reason

YES, policy xyz, events, abcsee reference

■ Go through all 133 controls

■ Say whether applicable or not

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Management Reviews

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Management Reviews

■ The RTP owners periodically take stock of the ISMS – is it effective?

Is the ISMS effective?

And what about the future?

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Effectiveness - Metrics

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ISMS Requirement

■ There are numerous requirements concerning metrics and incident handing

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Metrics ■ 1 - %CFES = (TCFES / TC) x 100

where TCFES = ∑ co-workers who have received training in security, and TC = Total no. of co-workers

■ F – PFS = (IPF / TIS) x 100where IPF = ∑ Security incidents caused by lack of training, and TIS = Total no. of security incidents

■ 1 - %SPSM = (TSP / TSA) x 100where TSP = ∑ Information systems protected from malware, and TSA = Total number of systems threatened by malicious software

Extracts from New ISO Work Item on ISMS metrics

■ Need to assess effectiveness of ISMS

■ Guidance will be in ISO/IEC 27004 – still under development

■ Detect event in sufficient time to prevent or mitigate impact

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ISO/IEC 17799Code of Practice for Information Security Management

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©Gamma Secure Systems Limited, Wm List & Co., 2006

ISO/IEC 17799■ Security Policy■ Organising Security■ Asset Management■ Human Resources Security■ Physical and Environmental Security■ Communications and Operational Management■ Access Control■ Information Systems Acquisition, Development and

Maintenance■ Information Security Incident Management■ Business Continuity Management■ Compliance

• Prior to employment• During employment• Termination or change of employment

• Roles and responsibilities• Screening• Terms and conditions of employment

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Certification

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Certification

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International Take-up

May 2006

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Benefits

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Benefits■ Reduction in insurance premium paid for

project

■ New customers

■ Avoided customer penetration testing

■ Security become a team effort, including managers, everyone more aware

■ Documentation corresponds to reality

■ Corporate internal audit very happy

■ Management is in charge

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Transition to ISO/IEC 27001

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UKAS Transition Statement

■ Up until 23 July 2006 audits 7799 or 27001

■ After 27001 only

■ Non-conformities against 27001 must be cleared by 23 July2007

■ Accredited BS 7799-2 certificates will be invalid after 23 July 2007

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Conversion 7799 to 27001■ Many minor changes

prompt detection of errors, events and impacts ..."

■ SOA changesShuffle of controlsSmall number

additions/deletions ■ Gamma’s CB (BSI) wanted to see

the conversion plan

■ Main changes Introduced measurement

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RELATION WITH OTHER STANDARDS, LAWS and REGULATIONS

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Corporate governance & internal control

■ … a result of scandals … investing public … being "ripped off" … conduct of senior executives South Sea Bubble, Kruger, Salad

Oil company, Equity Funding, Polly Peck, Maxwell Pensions, Enron, WorldCom …

■ New laws/regulations … anti discrimination, privacy protection, product quality, environment etc. 

■ Turnbull, OECD, Sarbanes-Oxley, EU directive

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Sarbanes-Oxley/EC Directive■ An act “to protect investors by improving the

accuracy and reliability of corporate disclosures made pursuant to the security laws, and for other purposes”

■ Places heavy emphasis on internal control, e.g.§404 (a) (1) state the responsibility of management

for establishing and maintaining an adequate internal control structure and procedures for financial reporting.

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Basel II■ Extends credit/market risk provisions of Basel 1 to

operational riskThe risk of direct or indirect loss resulting from

inadequate or failed internal processes, people and systems, or from external events

■ Encourages establishment of effective internal control to release Tier 1 capital

■ Can you demonstrate effective control to satisfaction of the regulators?

■ You will need to be able to measure effectiveness

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Internal ControlA WORD OF WARNING

In US Only financial reporting

In UK Everything

In INDIA Rule 49 Financial reporting + risk management

Definitions differ around the world!

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Information Security■ ISO/IEC 15408 “Common Criteria” – IT security

product evaluation

■ Various technical standards: encryption, intrusion detection, biometrics, smart cards, etc.

■ Laws and regulations: companyacts, data protection acts, lawsconcerning cryptography anddigital signatures, Sarbanes-Oxley,Basel II, various cyber laws …

www.globalplatform.org

Does the product possess vulnerabilities that an attacker

can exploit to harm the information the product is

intended to protect?

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Relationship

■ ISO/IEC 27001 is a management standard

■ It is the glue, whereby management can: ensure compliance with laws and regulations marshal the benefits of technical standards

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METHODOLOGY

The Advanced Web-based Internal Control Management System

Methodology (AWICMSM)

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©Gamma Secure Systems Limited, Wm List & Co., 2006

Methodology

■ ISMS is just part of Internal Control

■ Measuring effectiveness – the TIME theory

■ Events and Impacts – tell it like a story

■ The SOA is just an “AIL” – alternative ideas list

■ Integrated Management Systems

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The “TIME” Theory

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Event-Impact Relationship

“… detect the event in sufficient time to do something positive about it… “

See http://www.gammassl.co.uk/topics/time/index.html

■ There is a fundamental principle of internal control (and thus ISMS):

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Fundamental Model (too late)

Cost of ICS, CICS

Cost of business activities, CBA

Time

Mon

ey (£

)

Revenue, R

P

TE TW

P

TM TF

PP

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Fundamental Model (in time)

Cost of ICS, CICS

Cost of business activities, CBA

Time

Mon

ey (£

)

Revenue, R

P

TE TWTD TF

P

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Types of Control■ Detective

Identify when some event, or events have occurred … and invoke appropriate actions to arrest (or mitigate) the situation

■ Preventive Either prevent the event from occurring or affecting the organisation, or Detect the event as it happens and prevent any further activity that may

lead to an impact

■ Reactive Identify that the impact has occurred and invoke appropriate actions to

recover (or mitigate) the situation

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Control Spectrum

Fails to detect the event and does not have a BCP 7

Fails to detect the event but does have a BCP6

ReactiveFails to detect the event but has a partially deployed BCP 5

Detects the event but cannot react fast enough to fix it within the time window

4

Detects the event and just reacts fast enough to fix it within the time window

3

DetectiveDetects the event and reacts fast enough to fix it well within the time window

2

PreventivePrevents the event, or detects the event as it happens and prevents it from having any impact

1

TypeAbility to detect the event and take recovery action

Class

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A Disaster Recovery (1966)■ Saw warehouse on fire whilst

landing at Heathrow

■ Fire brigade – no building plans ∴ delays in fighting fire

■ List of people to tell had been burnt

■ Worried relations jammed switchboard

■ No one knew where the staff were as that list had been burnt

■ But, IT rescued the tapes during escape

■ Lessons: Know what to do for first

24/48hrs Designated jobs:

• decision maker• loss adjuster• emergency services• staff, friends and relatives

Have copy records off site

■ Type 5, 6 or 7? Type 6, but must test and

practise

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Measurement

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ISMS Requirement

■ There are numerous requirements concerning metrics and incident handing

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We Can Measure Things…

■ 1 - %CFES = (TCFES / TC) x 100where TCFES = ∑ co-workers who have received training in security, and TC = Total no. of co-workers

■ F – PFS = (IPF / TIS) x 100where IPF = ∑ Security incidents caused by lack of training, and TIS = Total no. of security incidents

■ 1 - %SPSM = (TSP / TSA) x 100where TSP = ∑ Information systems protected from malware, and TSA = Total number of systems threatened by malicious software

Extracts from New ISO Work Item on ISMS metrics

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Interpreting the Results

■ Perfect

■ On target

■ Below target, but close

■ Way below target

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What Have We Measured?

■ Performance

■ Whether on track for a given target

■ Identifying areas for improvement

■ All of these are valid, but are they really a measure of ISMS effectiveness?

■ How do I know the ISMS is working?

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This is How …

Scope •Policy •

Risk Assessment (RA) •Risk Treatment Plan (RTP) •

Statement of Applicability (SOA) •Operate Controls •

Awareness Training •

Prompt Detection and Response to Incidents •Manage Resources • •Internal ISMS Audit

•Management Review

•Corrective Action

•Preventive Action

•ISMS Improvements

Good design should ensure that ISMS detects

all events in sufficient time…

If not there will be an incident Need other checks as

well

May need to take action

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Incidents?■ Safe found unlocked

■ Blue death

■ Hard disc crash

■ Adware virus

■ Fox hunting protestors

possible unauthorised disclosure

usually no impact

ditto

possible unauthorised disclosure

adverse press coverage

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Definition of an Incident

“… an occurrence of an impact… “

NOT the occurrence of a threat or vulnerability

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A Practical Proposition (1)■ Deal with incidents and metrics together

■ There is a page that does this (“ISMS Metrics and Incident Handling”)

■ Uses definition incident = occurrence of impact

■ Metric is just the time metric

■ Can add others if needed

■ There is a template incident handling procedure

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A Practical Proposition (2)■ Fill in an impact record and log

it to record: The event, together with a

reference to the RTP The impact The values of TE, TD/TM, TF and TW

(see ISMS Metrics and incident Handling section of skeleton)

The value of IP (and if possible the cost of the existing controls)

■ Monitor these records at: Management meetings ISMS audit visits

Here is the blank record

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UK Bank

Use of time theory for Basel II

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Tell it Like a Story

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So What Makes a Good RTP?

■ The senior management, as a whole can understand the risks together participate in determining optimum countermeasures to risk allocate the overall ‘control’ spend to various risks across the whole business

■ All staff concerned with design, implementation or performance of controls to understand why the control is necessary to determine when an implementation of a control fails to meet its objective to understand how failures in a control are detected

■ Enables prompt revisions to be undertaken as circumstances change or incidents occur

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Approach■ Performed by risk

owners – the Board

■ Tell it like a story

■ Business events and impacts

■ Public methodologyGood plotHappy ending

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Events and Impacts

■ Expressed in business terms, they are what worry people

■ The event: an aircraft engine fails on take-off

■ Impacts:Potential loss of lifeDissatisfied customersIncreased costs

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Typical IS Events and Impacts■ Theft

■ Acts of God, vandals and terrorists

■ Fraud

■ IT failure

■ Hacking

■ Denial of service

■ Disclosure

■ Breach of the law

■ Adverse press coverage

■ Organisation ceases trading

■ Inability to carry out all or some of its business

■ Loss of customer confidence

■ Loss of revenue

■ Increased costs

■ Prosecution

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Example

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Example (continued)

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Example (continued)

Risk S x All the other issues

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Alternative Ideas Lists

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The AIL Concept■ Policy/RTPs should have identified all controls, but has

anything been overlooked?

■ What do other people do?

■ What do they do that applies to us?

■ If it applies do we do it?

■ This is just what the SOA is about

■ SOA “Alternative Ideas” List (AIL)

■ It is a “safety net”

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Multiple AILs■ In reality there are multiple AILs

■ ISO/IEC 17799:2005 is just one such list, but there are many others, corresponding to:CobiTCOSO/ITGIQuality assurance (ISO 9001) IT Service Management (ISO/IEC 20000 )Environmental protectionVulnerability testingFinancial accountingDifferent lists for different legal jurisdictionsEtc.

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Extract of ITGI Guidance

Mapping of CobiT to

PCAOB IT general controls

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Extracts from ITGI Guidance

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ISO 9001:2000 AIL

■Planning of Product Realisation■Customer Related Processes■Design and Development■Purchasing■Product and Service Provision■Control of Monitoring and Measuring

Devices

Applicable/non-applicable requirements under 6 major headings (Section 7 of ISO 9001)

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Integrated Management Systems

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Overall Model

PolicyBusiness Risks

Applicable/non- applicable risks

Risk Treatment Plans SOAs

AILs

Safety net

Business Objectives

Mission

Control Processes

Manage resourcesTraining, competence, awarenessPrompt reaction to incidents

Operational Processes ReviewInternal auditManagement reviewRoutine checks, etc.

Act

Corrective actionPreventive actionImprovements

PLAN

DO CHECK

ACT

Superposition of UK Audit Practices Board model and ISO/IEC 27001

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Integrated Management Systems

■ One MS, one audit, many standards

■ BSI call it the shape of the future

■ Gamma hasone

PolicyBusiness Risks

Applicable/non- applicable risks

Risk Treatment Plans SOAs

AILs

Safety net

Business Objectives

Mission

Control Processes

Manage resourcesTraining, competence, awarenessPrompt reaction to incidentsCustomer feedback, etc

Operational ProcessesReview

Internal auditManagement reviewRoutine checks, etc.

Act

Corrective actionPreventive actionImprovements

PLAN

DO CHECK

ACTBS 7799-2

And ISO 9001

And …

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Taking it from the Top■ Mission

■ Business objectives

■ Business risks

■ RTPs

CREDIT RISK

MARKETRISK

OPERATIONAL RISK

1

2

345

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Internal Control

■ There are two parts to internal control: Processes/procedures for“doing the work” (Part 1)“ensuring the work is done properly” (Part 2)

■ Part 2 are the controls (Events, Impacts and RTPs)

■ What about Part 1?

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Opportunities and Benefits■ The converse of events and impacts

■ Have Opportunity Exploitation Plans (OEPs) rather than RTPs

■ Similar “time” theory

Reaping the benefit Loosing the opportunity

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Enhanced PDCA Framework

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Summary

■ Unified methodology

■ ISMS is part of internal control …

■ … but is also the engine that drives it

■ Time theory: RTPs and OEPs

■ AIL safety net

■ Facilitates creation of an integrated management system

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COMMERCIAL APPLICATION

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Overview■ Classroom/on-the-job training,

throughout at least one PDCA cycle

■ Role Model

■ Skeleton ISMS

■ To-Do-List concept

■ Event-impact RTPs

■ Integrate with existing internal control structures

■ Marshal existing procedures/ records

■ Overarching/subordinate ISMS

■ Case study – Government of Mauritius

4 -6 months

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Implementation ApproachesCurrent security controls are “good enough”

YES NO

“Chauffer” driven

Client “drives”

We build the ISMSand run it for you

We train/tutor you.You build and run

We advise. You buy/ implement

We advise, buy and implement

Teams led by a world expert

15 daysto build ISMS

Build ISMS first, then do other things

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Role Model

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InformationISMS

Acts to reduce riskto acceptable level

Informationusers

Use

Instruct and monitor

ISF

Owns/looks after

Owns

ISMSAdministratorProvides

managementinformation

Direct

Manages

PolicyMakers

Set organisation-wide policy

Provide feedback/request policyenhancements

InternalISMS

Auditors

CertificationAuditors Certify

Audit

Provide feedbackProvide feedback

ISMSAdvisor

Advise

Advise

Advise

ISMSTrainer

Train

Advise

Role Model

■ Information Security Forum (ISF)

■ ISMS Administrator

■ Internal ISMS Auditor

■ ISMS Trainer

■ ISMS Advisor

■ Certification auditor (optional)

■ Policy Maker

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The To-Do-List Concept

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The “To-Do-List” Concept■ Management standards, including ISO/IEC 27001

insist that the management processes must be in place

■ But new security processes may be required because risks change

■ At any point in time:Existing security procedures in placeNewly identified ones still-to-do

■ Managed using a “To-Do-List”

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The “To-Do-List” Concept■ Management standards, including ISO/IEC 27001

insist that the management processes must be in place

■ But new security processes may be required because risks change

■ At any point in time:Existing security procedures in placeNewly identified ones still-to-do

■ Managed using a “To-Do-List”

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Non ConformitiesA non-conformity "is the absence of, or failure to implement and maintain, one or more required management system elements, or a situation which would, on the basis of objective evidence raise significant doubt as to the capability of the ISMS to achieve the security policy and objectives of the organisation."

This definition comes from EA7/03

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Which Means…is the absence of, or failure to implement and maintain, one or more required management system elements

or a situation which would, on the basis of objective evidence raise significant doubt as to the capability of the ISMS to achieve the security policy and objectives of the organisation

Missing/failed ISMS infrastructure component

Missing/failed Applicable controls

leading to significant doubt ...

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Which means …■ Management standards, including ISO/IEC 27001

insist that the management processes must be in place

■ But new security processes may be required because risks change

■ At any point in time:Existing security procedures in placeNewly identified ones still-to-do

■ Managed using a “To-Do-List”

■ Can have entries in progress

■ Entries will be corrective, preventive or improving in nature

■ There should be evidence that any risk is being managed

Don’t like what you do now – declare as a non-acceptable risk in the near future

and put on the To-Do-List

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Skeleton ISMS

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Skeleton ISMS Parts for you to complete

Covers every requirement of ISO/IEC 27001

Version control

Checklists

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Skeleton ISMS■ Built-in facility for document

control

■ Space to define scope and context

■ Prototype policy

■ Provision for RTPs

■ Virtually AILs (with built-in hyperlinks to policy statements and standard events)

■ Facility for including training and awareness

■ Internal audit proforma and checklist

■ Management system review checklist

■ Procedures for corrective action etc.

■ To-Do-List and associated procedures

■ Records

■ Compliance index

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Skeleton ISMS

■ There is space to define the ISMS scope, just as it will appear on the 27001 certificate

■ And to define the ISMS context

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Skeleton ISMS■ There is a prototype

ISMS policy

■ Most words are there to ensure compliance with the standards

■ Some to simplify production of the SOA

■ Customise with reference to relevant corporate policies

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Skeleton ISMS

RTP TEMPLATE

■ Provision to develop RTPs

■ The standard eight plus any others

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Skeleton ISMS■ SOA with hyperlinks

to the standard eight events and policy statements

■ Skeleton included links to common policies and procedures

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Skeleton ISMS■ There is a facility for recording training and awareness

activities for all staff

■ Just amend/reference what you do

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Skeleton ISMS■ Page on Metrics/

Incident Handling

■ Uses time theory

■ Incident is occurrence of impact

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Skeleton ISMS■ An internal ISMS audit

schedule

■ Procedure, proforma report and checklist (ensures compliance when completed)

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Skeleton ISMS■ Initial management

review schedule

■ Procedure and checklist (for the meeting secretary, which also ensures compliance when completed)

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Skeleton ISMS■ Procedure for dealing

with preventive, corrective actions and improvements

■ To-Do-List

■ Record and document control section for all ISMS records

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Conformance with Standard

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Overarching and Subordinate ISMSs

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Overarching & Subordinate ISMSs

■ For complex organisations

■ Facilitates promulgation of common policies/procedures

■ Ensures significantly less work to create ISMS

■ Ensures management concentrate RTPs on own areas of responsibility

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Cabinet Office

Ministry #1 Ministry #2

Overarching & Subordinate ISMSs

Head Office

Subsidiary #1 Subsidiary #2IT Department .. HR .. Legal .. Sales & Marketing .. Research ..

Executive Board

Overarching ISMS

Subordinate ISMS Subordinate ISMS

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Overarching & Subordinate ISMSs

Overarching ISMS

Subordinate ISMS

Top Level RTPs

High level policy statements

Common Controls

SubordinateRTPs

SubordinateSpecific Controls

Common procedure

Subordinate specific

Determine overall effectiveness

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Summary

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What Makes the Approach Fast■ Addresses all the issues:

Scope, Policy, Risk Assessment/ Treatment, SOA, Gap Analysis, …

■ Skeleton means that everything that needs to be done only once is done only once

■ Facilitates a well organised project

■ Instils confidence to succeed in participants

■ Creates information security awareness

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CASE STUDY

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The Civil Service of Mauritius

■ Small island off the southeast coast of Africa in the Indian Ocean

■ 2,000 km from Durban, 6000 km from Perth, 9700 km from London

■ Area: 1865 km2

■ Population: 1.2 m

■ Multi-cultural society (66% Indian, 31% African & European, 3% Chinese)

■ Free & compulsory education

■ Bilingual (English, French)

■ 90% literacy rate

■ Free health services

■ Sub Tropical Climate (19oc - 29oc)

Source: Ministry of IT & Telecommunications, Mauritius

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The Mission

■ Develop ICT as the 5th Pillar of the Economy

■ Critical success factors include information security, as well as leadership, legislation, infrastructure, e-culture, marketing, etc.

■ Drivers:Security seen to be an IT issueLack of information security awarenessGreater emphasis on technical controls rather than

management controlsRisk management fairly new to many organizations

Source: Ministry of IT & Telecommunications, Mauritius

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The Information Security Journey

■ Task Force on Security Standards adopts 7799 (2000)

■ Establish Steering Committee and plans (2001)

■ Government approval of plans (2002)

■ Invite tenders for consultancy (2002)

■ Consultancy project to train staff and take four “pilots” through to certification(2003)

■ Rollout to all other Ministries and Departments (2004-6)

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Project TimescalesStart of Training

ISMSs Certified

4 months

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Approach■ ISMS built by people who will own it

■ Training to ALL involved with the ISMS

■ Use of Skeleton ISMS to ‘fast track’ creation of actual ISMS manual

■ Stylised approach to creating RTPs, based on events and impacts

■ To-Do-List to manage implementation of improvements and additional security requirements

Standard Skeleton Standard Skeleton ISMS ManualISMS ManualConformity with:Conformity with:1. BS 7799-21. BS 7799-2

Upgraded Skeleton Upgraded Skeleton ISMS ManualISMS ManualConformity with:Conformity with:4.4. BS 7799-2BS 7799-25.5. Govt policiesGovt policies

Departmental SkeletonDepartmental SkeletonISMS ManualISMS ManualConformity with:Conformity with:4.4. BS 7799-2BS 7799-25.5. Govt policiesGovt policies6.6. Dept policies, lawsDept policies, laws7.7. Dept. RTPsDept. RTPs

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Pilot Implementation Framework

■ Steering Committee

■ Pilot Site Information Security Forum Ministry of Social Security (Contributions, Benefits, …) Passport & Immigration Office (passport, residence permit, visa,

border control, …) Civil Status Office (Birth, Death, Marriage registration, …) Treasury Department (Govt. Accounting System, Budget

monitoring, pensions, …) Head or Deputy as Project Leader Team (Head and/or Deputy, Senior Officers)

■ ISMS Advisors/Consultants

■ Internal ISMS Auditors

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Training Programme■ Coverage

BS 7799-2 and Methodology

Risk Treatment Plans ISMS Skeleton Internal ISMS AuditingComputer Assisted

Audit Techniques

■ AudiencePilot ISMS

Development TeamsManagement ISMS Advisors Internal ISMS Auditors

On-the-Job TrainingOn-the-Job Training

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Skeleton ISMS Manual

Parts for the Pilots to complete

Covers every requirement of BS7799-2:2002

Checklists

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Risk Treatment Plans

■ Departments chose “departmental specific” events and worked on thosefirst

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Method of Working

■ Teams worked largely ontheir own with supportfrom:The new ISMS AdvisorsThe Consultants

■ Starting with the “business”events worked well

■ The traditional RTPs ran smoothly as Senior Management now knew what questions to ask

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To-Do-Lists

■ Each created a To-Do-List

■ These did not prove a bar to certification

■ Demonstrated information security management

■ The ISMS owners made these decisions

Source: Ministry of IT & Telecommunications, Mauritius

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Auditing and Certification

Internal Internal AuditingAuditing MandatoryMandatory

IT Security Unit/IT Security Unit/Dept InternalDept Internal

AuditorsAuditors

Desktop AuditDesktop Audit

ImplementationImplementationAuditAudit

External External AuditingAuditing DesirableDesirable

MauritiusMauritiusStandardsStandards

BureauBureau

““Certification”Certification”

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Feedback

■ Resource Availability

■ Expertise of ISMS Team

■ Commitment of Senior Management

■ Tight Schedule

■ Lack of confidence

■ Security Awareness

■ Higher Confidence

■ Security Culture

■ Empowerment

■ Improved Security

■ Enriching experience

■ Feeling of SatisfactionSource: Ministry of IT & Telecommunications, Mauritius

BEFORE AFTER

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Observation

■ By involving very seniorstaff in developing theRTPsThey own the

information security problemThey lead from the topThey believe in its importanceTheir immediate staff know thatIt is a powerful way of creating awareness

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Institutional Framework

PMO

Other ministries

MinisterialSecurity Officers

Committee

An ISMS

IT Security Unit

MIT

T

PMO Security Division

ISMSs

Overarching ISMS

RTPs for central policies

(Registry, Personnel, Finance, …)

CentralSkeleton

ISMS

Subordinate ISMSs

(MinistriesDepts)

Rollout

■ Prioritisation of Sites

■ Certification

■ Marketing & Promotion

■ ISO/IEC 17799 as National Standards

Source: Ministry of IT & Telecommunications, Mauritius

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Current Status

■ Rollout to other Ministries and Departments proceeding to plan

■ It is clear that the training worked

■ To a large extent it was marshalling what the Departments already had, rather than inventing something new

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SUMMARY

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Summary■ ISO/IEC 27001, risk

driven PDCA management system standard

■ Methodology: time theory governing effectiveness, places ISMS at heart of internal control

■ RTP method allows senior management to own the information security problem

■ Extensible using AILs and OEPs to cover whole of internal control

■ Practical implementationFast track approachSkeleton ISMS

■ Practical experience

■ Methodology can be taught and applied easily by others

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Further InformationThe papers referred to in this

presentation can be found at

www.gammassl.co.uk/topics/ics/html

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Information Security Management

ISO/IEC 27001 and Internal Control

Dr. David Brewer

Mr. William List, CA, hon FBCS