(ISC)2 CISSP Certified Information Systems Security Professional Official Study Guide. Mike Chapple
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Industry Data Security Standard [PCI DSS] to maintain the ability to perform credit card processing); only then can they be held accountable for violations or lacking compliance. Compliance is a form of administrative or managerial security control because it focuses on policies and people abiding by those policies (as well as whether the IT and physical elements of the organization comply with policies).
Compliance enforcement is the application of sanctions or consequences for failing to follow policy, training, best practices, and/or regulations. Such enforcement efforts could be performed by the chief information security officer (CISO) or chief security officer (CSO), worker managers and supervisors, auditors, and third-party regulators.
Compliance is also a regulation concern. That topic is covered in Chapter 4.
Privacy Policy Requirements
Privacy can be a difficult concept to define. The term is used frequently in numerous contexts without much quantification or qualification. Here are some partial definitions of privacy:
Active prevention of unauthorized access to information that is personally identifiable (that is, data points that can be linked directly to a person or organization), known as personally identifiable information (PII)
Freedom from unauthorized access to information deemed personal or confidential
Freedom from being observed, monitored, or examined without consent or knowledge
When addressing privacy in the realm of IT, there is usually a balancing act between individual rights and the rights or activities of an organization. Some claim that individuals have the right to control whether information can be collected about them and what can be done with it. Others claim that any activity performed in public view—such as most activities performed over the internet or activities performed on company equipment—can be monitored without knowledge of or permission from the individuals being watched, and that the information gathered from such monitoring can be used for whatever purposes an organization deems appropriate or desirable. Some of these issues are determined by law based on country or context, whereas others are left up to organizations and individuals.
Protecting individuals from unwanted observation, direct marketing, and disclosure of private, personal, or confidential details is usually considered a worthy effort. However, some organizations profess that demographic studies, information gleaning, and focused marketing improve business models, reduce advertising waste, and save money for all parties.
There are many legislative and regulatory compliance issues in regard to privacy. Many U.S. regulations—such as the Health Insurance Portability and Accountability Act (HIPAA), the Sarbanes–Oxley Act of 2002 (SOX), the Family Educational Rights and Privacy Act (FERPA), and the Gramm–Leach–Bliley Act—as well as the European Union's General Data Protection Regulation (GDPR) (Regulation [EU] 2016/679)—include privacy requirements. It is important to understand all government regulations that your organization is required to adhere to and ensure compliance, especially in the areas of privacy protection.
Whatever your personal or organizational stance is on the issue of online privacy, it should be addressed in an organizational security policy. Privacy is an issue not just for external visitors to your online offerings but also for your customers, employees, suppliers, and contractors. If you gather any type of information about any person or company, you must address privacy.
In most cases, especially when privacy is being violated or restricted, the individuals and companies may need to be informed; otherwise, you may face legal ramifications. Privacy issues must also be addressed when allowing or restricting personal use of email, retaining email, recording phone conversations, gathering information about surfing or spending habits, and so on. All this and more should be codified in a privacy policy (i.e., internal rules) and potentially a privacy statement/disclosure/notice (i.e., explanation to external entities).
Privacy and PII are covered more in Chapter 4.
Understand and Apply Risk Management Concepts
Risk management is a detailed process of identifying factors that could damage or disclose assets, evaluating those factors in light of asset value and countermeasure cost, and implementing cost-effective solutions for mitigating or reducing risk. The overall process of risk management is used to develop and implement information security strategies that support the mission of the organization. The results of performing risk management for the first time is the skeleton of a security policy. Subsequent risk management events are used to improve and sustain an organization's security infrastructure over time as internal and external conditions change.
The primary goal of risk management is to reduce risk to an acceptable level. What that level actually is depends on the organization, the value of its assets, the size of its budget, and many other factors. One organization might consider something to be an acceptable risk, whereas another organization might consider the very same thing to be an unreasonably high level of risk. It is impossible to design and deploy a totally risk-free environment; however, significant risk reduction is possible, often with modest effort.
Risks to an IT infrastructure are not all computer based. In fact, many risks come from non-IT sources. It is important to consider all possible risks when performing risk evaluation, including accidents, natural disasters, financial threats, civil unrest, pandemics, physical threats, technical exploitations, and social engineering attacks. Failing to properly evaluate and respond to all forms of risk will leave a company vulnerable.
Risk management is composed of two primary elements: risk assessment and risk response.
Risk assessment or risk analysis is the examination of an environment for risks, evaluating each threat event as to its likelihood of occurring and the severity of the damage it would cause if it did occur, and assessing the cost of various countermeasures for each risk. This results in a sorted criticality prioritization of risks. From there, risk response takes over.
Risk response involves evaluating countermeasures, safeguards, and security controls using a cost/benefit analysis; adjusting findings based on other conditions, concerns, priorities, and resources; and providing a proposal of response options in a report to senior management. Based on management decisions and guidance, the selected responses can be implemented into the IT infrastructure and integrated into the security policy documentation.
A concept related to risk management is risk awareness. Risk awareness is the effort to increase the knowledge of risks within an organization. This includes understanding the value of assets, inventorying the existing threats that can harm those assets, and the responses selected and implemented to address the identified risk. Risk awareness helps to inform an organization about the importance of abiding by security policies and the consequences of security failures.
Risk Terminology and Concepts
Risk management employs a vast terminology that must be clearly understood, especially for the CISSP exam. This section defines and discusses all the important risk-related terminology:
Asset An asset is anything used in a business process or task. If an organization relies on a person, place, or thing, whether tangible or intangible, then it is an asset.
Asset Valuation Asset valuation is value assigned to an asset based on a number of factors, including importance to the organization, use in critical process, actual cost, and nonmonetary expenses/costs (such as time, attention, productivity, and research and development). When performing a math-based risk evaluation (i.e., quantitative; see the “Quantitative Risk Analysis” section, later in this chapter), a dollar figure is assigned as the asset value (AV).
Threats Any potential occurrence that may cause an undesirable or unwanted outcome for an organization or for a specific asset is a threat. Threats are any