Governance, Risk Management and Compliance Flashcards
Control Framework
Examples
These are used to create a governance program to enable compliance with security and privacy requirements
ISO 27014 - Governance of Information Security
ISO 38501 - Governance of Information Technology
What characteristics should control frameworks have?
Consistent - in line with Sr. Mgmt guidance and expectations with regards to security and data privacy goals
Measurable - provides a way to determine progress and set goals or KPIs
Standardized - rely on standards or results from one organization or part of an organization that can be compared in a meaningful way
Comprehensive - Should cover the minimum legal and/or regulatory requirements
Modular - A framework that can withstand the changes of an organization because the controls or requirements needing modification are reviewed and updated
Governance
Ensures the business focuses on core activities, clarifies WHO in the organization has the authority to make DECISIONS, create POLICY, determines ACCOUNTABILITY for actions and RESPONSIBILITY for outcomes and addresses how expected performance will be evaluated.
Compliance
Refers to actions that ensure behavior complies with established rules/policies
Data Subject
An individual who is the subject of personal data
Data Steward
Responsible for data quality, content, context, and associated business rules
from class “responsible for data integrity”
Data Owner
Hold legal rights and complete control and accountability of a single piece or set of data elements
usually the department head or business unit manager for the office that has created or collected a certain dataset.
The data owner will be identified in the create phase.
Data Custodian
Responsible for the safe custody, transport, storage of the data and implementation of business rules
The data custodian is any person or entity that is tasked with the daily maintenance and administration of the data. The custodian also has the role of applying the proper security controls and processes as directed by the data owner.
Data Controller
A person who determines WHY and HOW PERSONAL DATA is processed
Data Processor
Any person who processes data on behalf of the data controller
Data Protection Officer (DPO)
Normally APPOINTED by the Data Controller and Data Processor
Responsible for ensuring the strategy and implementation of DATA PROTECTION requirements are in COMPLIANCE with data standards/requirements/laws (e.g. GDPR)
Due Care
Setting best or reasonable practices as a responsible organization should do
“Do the Right Thing”
Every employee in the organization should do their job correctly, following policies, procedures, and best practices
The company did all it could have reasonably done to prevent.. breach, what ever…
They exercised due care
Note: Auditors care about due care
Due Diligence
Providing a record or history of compliance and enforcement
Providing evidence that you are doing the right thing.. e.g. proof a policy was followed
Note: Auditors care about due diligence
Corporate Governance
the system of rules, practices, and process by which a company is directed and controlled
begins with policy
- Policies?
Corporate Policies?
- the foundation of corporate governance
Mandatory rules, practices and processes authorized and sponsored by Sr. Mgmt and followed by everyone under penalty if broken
- Requirements derived from regulatory/legal, contractual, or social/ethical compliance
How is Policy Implemented?
Management must adopt:
Standards/Frameworks
Baselines
Procedures
Guidelines
How should you adopt standards/frameworks to implement policy?
HW, SW, documents are deployed universally throughout the organization
Specific technologies are used in uniform ways
Standards are mandatory, everyone must follow them
How should baselines be used to implement policy?
The minimum level of protection or settings for specific platforms or environments should be established as a baseline
Baselines are derived from standards and are mandatory
How should Procedures be used to implement policy?
Step by step required and mandatory actions on how to accomplish or maintain the directives of the policy should be documented and followed
How should Guidelines be used to implement policy?
Not mandatory but used as best practices, recommendations, suggestions or advice for accomplishing a goal
e.g. optional, non-binding
Executive committees for governance
- Purpose
- Who is on the committee
- Determine Organizational requirements and determine Governance, Risk Management and Compliance
- Board of Directors, Shareholders, Stakeholders and Senior Management
Risk Management
identifying threats and vulnerabilities and quantifying and addressing risk associated with them
identify industry, legal and regulatory requirements and addressing risk associated with them
a cyclic, systematic process for monitoring, identifying, analyzing, evaluating/assessing risk to determine risk response: mitigating, transferring, avoiding, and accepting risk
To mitigate or reduce risk to acceptable levels
Includes Risk Analysis, Cost/Benefit Analysis, Deploying counter measures or safeguards, auditing, insurance, Business Continuity Planning, education, training, etc.
What measure does a Qualitative Risk Assessment use to assess risks?
Qualitative risk assessments use nonnumerical categories that are relative in nature, such as high, medium, and low. Quantitative assessments use specific numerical values such as 1, 2, and 3.
Risk Appetite
AKA, Desc
Risk appetite is the level, amount, or type of risk that the organization finds acceptable.
Organization is prepared to accept this amount or level of risks to meet its objectives
AKA Risk Tolerance
Organizations have four main ways to address risk?
Avoidance
Acceptance
Transference
Mitigation
Risk Avoidance
removing the technology or activity to remove the risk
it means leaving a business opportunity because the risk is simply too high and cannot be compensated for with adequate control mechanisms—a risk that exceeds the organization’s appetite.
Risk Acceptance
What should never happen with respect to managing risk?
AKA
The opposite of avoidance; the risk falls within the organization’s risk appetite, so the organization continues operations without any additional efforts regarding the risk
NEVER accept risk without avoiding, mitigating and transferring as much as possible based on business/compliance/due care conditions
Risk Retention
Risk Transference
The organization pays someone else to accept the risk, at a lower cost than the potential impact that would result from the risk being realized; this is usually in the form of insurance or outsourcing. This type of risk is often associated with things that have a low probability of occurring but a high impact should they occur.