SECURITY MATURITY ASSESSMENT METHOD

Description

CROSS-REFERENCE TO RELATED APPLICATIONS

This application is a continuation, pursuant to 35 U.S.C. § 120, of U.S. patent application Ser. No. 10/134,815 filed on Apr. 29, 2002.

BACKGROUND OF INVENTION

Information Security encompasses the protection of information against unauthorized disclosure, transfer, modification, or destruction, whether accidental or intentional. Information security has become a prevalent concern of organizations as a result of the trends towards c-commerce, e-business, universal email and web access, and well-publicized security exploits. As a result, organizations are attempting to apply information security principles in a pragmatic framework.

To enable organizations to apply information security principles in a pragmatic framework, a number of information standards and tools have been developed. One widely recognized standard, BS7799/ISO17799, was developed by the British Standards Institution (BSI) and adopted by the International Organization for Standardization (ISO). The BS7799/ISO17799 standard is a comprehensive set of controls that outline best mode practices in information security. The aim of BS7799/ISO17799 is to serve as a single reference point to determine the appropriate information security policy for a variety of systems and organizations. The BS7799/ISO17799 standard includes 10 sections, each addressing a specific area of information security. See, “ISO17799 Security Standard: ISO 17799 Compliance & Positioning.”

The process of managing compliance with the BS7799/ISO17799 is a non-trivial task. As a result, a number of risk analysis and risk management products have been developed to help organizations comply with the BS7799/ISO17799 standard. One such product is COBRA, which was developed by C & A Systems, Inc. COBRA is used to semi-automate the assessment process. COBRA utilizes a series of online questionnaires to obtain information about the current security policy. Using the answers from the questionnaires, COBRA creates reports that provide information about the organization's current compliance position, on a pass/fail basis, with respect to each section of the BS7799/ISO17799 standard.

Another tool that has been developed to enable organizations to apply information security principles in a pragmatic framework is the Systems Security Engineering Capability Maturity Model (SSE-CMM). The SSE-CMM is derived from concepts of the Software Engineering Institute (SEI) Capability Maturity Model initially created for software development. The SSE-CMM describes the essential characteristics of an organization's security engineering process that must exist to ensure good security engineering. The SSE-CMM does not prescribe a process or standard such as BS7799/ISO17799, but rather uses a model that captures practices generally observed in the industry. Additionally, the SSE-CMM is based on a maturity model that defines specific goals and practices for the entire life cycle of an organization. Further, the SSE-CMM defines an overall assessment process and roles for security engineering within an organization. See, “System Security Engineering Capability Maturity Model-Model & Appraisal Method Summary April 1999.” The resulting assessment obtained from applying the SSE-CCM is typically not associated with a reporting tool to report the maturity level.

SUMMARY OF INVENTION

In general, in one aspect, the invention relates to a method for assessing an information security policy and practice of an organization, comprising determining a risk associated with the information security policy and practice, collecting information about the information security policy and practice, generating a rating using a security maturity assessment matrix, the collected information, and the risk associated with the information security policy and practice, generating a list of corrective actions using the rating, executing the list of corrective actions to create a new security information policy and practice, and monitoring the new security information policy and practice.

In general, in one aspect, the invention relates to an apparatus for assessing an information security policy and practice of an organization, comprising means for determining a risk associated with the information security policy and practice, means for collecting information about the information security policy and practice, means for generating a rating using a security maturity assessment matrix, the collected information, and the risk associated with the information security policy and practice, means for generating a list of corrective actions using the rating, means for executing the list of corrective actions to create a new security information policy, and means for monitoring the new security information policy.

In general, in one aspect, the invention relates to a computer system for assessing an information security policy and practice of an organization, comprising a processor, a memory, an input means, and software instructions stored in the memory for enabling the computer system under control of the processor, to perform determining a risk associated with the information security policy and practice, collecting information about the information security policy and practice using the input means, generating a rating using a security maturity assessment matrix, the collected information, and the risk associated with the information security policy and practice, generating a list of corrective actions using the rating, executing the list of corrective actions to create a new security information policy and practice, and monitoring the new security information policy and practice.

Other aspects and advantages of the invention will be apparent from the following description and the appended claims.

BRIEF DESCRIPTION OF DRAWINGS

FIG. 1 illustrates a typical computer system.

FIG. 2 illustrates a flowchart detailing the Security Maturity Assessment method in accordance with one embodiment of the invention.

FIG. 3 illustrates a portion of a Security Maturity Assessment Reporting Tool report in accordance with one or more embodiments of the invention.

FIG. 4 illustrates a flowchart detailing the Security Maturity Assessment method in accordance with another embodiment of the invention.

DETAILED DESCRIPTION

Exemplary embodiments of the invention will be described with reference to the accompanying drawings. Like items are denoted by like reference numerals throughout the drawings for consistency.

In the following detailed description of the invention, numerous specific details are set forth in order to provide a more thorough understanding of the invention. However, it will be apparent to one of ordinary skill in the art that the invention may be practiced without these specific details. In other instances, well-known features have not been described in detail to avoid obscuring the invention.

The invention relates to a method for assessing a security maturity of an organization. Further, the invention relates to assessing the security maturity of an organization using a security assessment matrix. Further, the invention relates to basing the security assessment matrix on the BS7799/ISO17799 standard and the Capability Maturity Model (CMM). Further, the invention relates to a method for providing quantitative, action-oriented results using the security assessment matrix. Further, the invention relates to a method to compare the security maturity of an organization to a pre-determined goal, or to the security maturity of the same organization at another point in time, or to the security maturity level mandated by another organization or authority.

The invention may be implemented on virtually any type computer regardless of the platform being used. For example, as shown in FIG. 1, a typical computer (28) includes a processor (30), associated memory (32), a storage device (34), and numerous other elements and functionalities typical of today's computers (not shown). The computer (28) may also include input means, such as a keyboard (36) and a mouse (38), and output means, such as a monitor (40). Those skilled in the art will appreciate that these input and output means may take other forms in an accessible environment.

The Security Maturity Assessment (SMA) method involves five distinct stages: (1) management awareness and commitment, (2) security maturity assessment, (3) corrective action plan (CAP), (4) corrective action plan execution (CAPE), and (5) ongoing monitoring. Each of the aforementioned stages is explained below in greater detail. Those skilled in the art will appreciate that the names used to denote the stages may vary without detracting from the invention.

FIG. 2 illustrates a flowchart detailing the SMA method in accordance with one embodiment of the invention. The SMA method is initiated by ensuring that an organization's management is aware and committed to improving the organization's information security practices and policies (Step 100). An assessment entity (e.g., individual/company conducting assessment) then assesses the organization's information security practices and policies (Step 102). Using the information gained in Step 102, the assessment entity develops a corrective action plan (Step 104). The corrective action plan is subsequently executed (Step 106). If the organization desires continuous monitoring after the execution of the corrective action plan (Step 108), then the assessment entity may continuously monitor revised information security policies and practices of the organization (Step 110). Following the continuous monitoring, the method may return to Step 100 to ensure that the organization's management is still aware and committed, or potentially proceed directly to Step 102 if the organization's management continues to be aware and committed. If the organization desires not to have continuous monitoring after the execution of the corrective action plan (Step 108), then the method ends.

The management awareness and commitment stage is the first stage of the SMA method and is used to raise awareness within the management of the organization being assessed and to initiate gathering of information. Specifically, in the management awareness and commitment stage, an assessment entity gathers information to understand the organization's business goals. Further, the assessment entity gathers information to understand the associated risks in terms of information security. For example, if the organization is using a wireless Local Area Network (LAN), there are different information security risks to consider than if the organization is using a conventional LAN where all computers are connected via Ethernet cable. Additionally, the assessment entity creates awareness in the organization by presenting the security maturity assessment methodology and method. In one or more embodiments of the invention, the assessment entity may also provide additional information about the underlying standards, e.g., the ISO standard. In one or more embodiments of the invention, the assessment entity may also provide an explanation of the concept of a maturity model as it applies to the security assessment.

The security maturity assessment stage is initiated by the assessment entity identifying participants required to perform the SMA. Additionally, the assessment entity, in conjunction with the organization, determines the effect and cost to be used to perform the SMA. A time line is also set to allow the assessment entity and the organization to have a means to track the progress of the SMA. At this point, in one or more embodiments of the invention, the assessment entity may request that the organization sign an assessment contract to ensure commitment by the organization to follow through with the SMA. Once the aforementioned steps have been completed, the assessment entity proceeds to perform the SMA.

The assessment entity initiates the SMA by collecting documents detailing the organization's existing information security policies and practices. After review of the collected documents, additional information is typically obtained via interviews with participants identified at the beginning of this stage. Using the information obtained from the collected documents and the interviews, a preliminary rating is generated. The preliminary rating details the maturity of individual sections and the overall maturity level of the organization's information security practices and policies.

In one or more embodiments of the invention, the preliminary rating is generated using a security assessment matrix (SAM). The SAM defines each level of maturity for each information security item, The SAM includes 61 rows corresponding to the groups of the BS7799/ISO17799 standard information security items, and 5 columns defining the maturity level. The five maturity levels, arranged from least mature to most mature, are Initial (Level 1), Repeatable (Level 2), Defined (Level 3), Managed (Level 4), and Optimizing (Level 5). For each intersection of row and column, there is a paragraph that defines a specific “capability maturity” level. The paragraphs contained in a given row of the SAM represent successive capability maturity levels for the same information security item. Further, some rows of the SAM represent successive capability maturity levels associated with a single information security item, as described in one paragraph of the BS7799/ISO17799 standard. Other rows of the SAM may represent successive capability maturity levels of information security items that the BS7799/ISO17799 standard describes in separate paragraphs or sections.

In one or more embodiments of the invention, an item definition for each information security item is included in the SAM. The item definition acts as a legend for the level definitions for a particular information security item. Further, in one or more embodiments of the invention, the SAM includes level definitions as follows: Level 1—Initial; Level 2—Not written down, but communicated via coaching; Level 3—Written down; Level 4—Responsibility is defined; Level 5—Process exists for catching deviations and improving the information security to prevent them. Further, in one or more embodiments of the invention, the SAM includes scope requirements. The scope requirements indicate to which various aspect of an organization's operations the criteria set forth in a particular row of the SAM must be applied.

The combination of a certain level definition (e.g., Level 1) with one information security item (i.e., a specific row of the SAM) yields a specific criterion that one skilled in the art can apply to establish if the organization being assessed meets, fails or exceeds this level of maturity for this information security item. Furthermore, those skilled in the art can apply the general definition of the maturity level (Level 1 through 5) to a specific information security item in such a way that they can readily determine whether the organization being assessed meets, fails or exceeds this level of maturity for this security item, even if the specific criterion set forth at the intersection of this row and column of the SAM is, for any reason, not directly applicable in the case of this organization.

Table 1 illustrates the SAM in accordance with one or more embodiments of the invention:

TABLE 1
Security Assessment Matrix

	Level 1	Level 2	Level 3	Level 4	Level 5	Scope
	(Initial)	(Repeatable)	(Defined)	(Managed)	(Optimizing)	Requirements

Level Definitions

						Process exists
						for catching
			Not written			deviations and
			down, but			making
ISO 17799	Item		communicated		Responsibility is	constant
Categories	Definitions		via coaching	Written down	defined	improvements

III.1	Information Security Policy	Coverage of	No security	Security policy	Specific	Security policy	Clear	Goal and
		Security Policy	policy in	exists, but as a	policy exists,	covers all areas of	responsibilities	principle of
		Review of effective	place	general	clearly stating	business. Security	and	every
		implementation of		statement.	in detail what	policy is owned by	mechanisms in	information
		information security		Inferring what	is mandated	appropriate functions	place to	security
		policy		is specifically	or prohibited.	including IT but also	upgrade policy	Information
		Review of		mandated or	A “normal”	Finance, HR, Legal,	if required	sharing
		Information		prohibited	person can	etc. Organization	after every	management
		Security Policy		requires	easily	policies define the	breach of	and
				consulting	understand it.	roles and	policy, also if	responsibilities
				specialized	Reviews	responsibilities in	business
				personnel. No	carried out at	following	changes
				regular reviews.	intervals, but	procedures. Reviews	(acquisition,
					no clear	carried out - intervals	divestiture, or
					management	and responsibility for	major changes
					responsibility	the reviews are	in process such
					to trigger	defined explicitly in	as
					reviews or	the policy.	outsourcing)
					exploit results		occur.
		Availability of	No security	Security policy	There is a	Security policy	Each security	Staff
		Security Policy to	policy	is discussed	Security	communication is	incident is	awareness and
		Employees	communication	with employees	Policy	part of written IT and	subject to a	education
		Security Education	to	and contract or	manual,	Personnel	post mortem	Responsibilities
		and Technical	employees	temporary	mentioned on	procedures. Training	procedure that	and
		Training	(non-	personnel upon	public notice	and/or	includes a	emergency
			existent, or	hiring.	board and/or	communication on	review of	arrangements
			limited to		on web page.	security policy occur	whether	Well defined
			IT			at least once a year.	applicable	policy
			personnel).				policies were	Security
							correctly	training
							communicated.	integrated into
							Users are	personnel
							taught the	development
							incident	program
							reporting	Management
							procedures.	responsibility
								to provide
								security
								training,
								including the
								specification
								of a clear desk
								and clear
								screen policy
								for all
								employees.
		Review of Security	Issued once,	Occasionally	Reviewed at	A clearly	There is a defined	General
		Process	never	reviewed if	intervals, but	designated person	mechanism to	management
			reviewed	senior	no clear	or body has	review and	responsibility
				management,	management	responsibility for	upgrade the
				auditors, etc.,	responsibility	the process, and	policy after every
				ask	to trigger	reviews it	security incident
					reviews of	regularly.	(is anything
					exploit results		missing from the
							policy that could
							have prevented
							the problem?)
IV.1	Information	Responsibility for	No	Specific	A matrix for	A specific party is	Security	Individual
	Security	the protection of	responsibility	individuals are	the	responsible for	responsibility is a	assets refer to
	Infrastructure	individual assets	is assigned.	aware of their	responsibility	defining and	required field in	the
				responsibility	of protection	maintaining the	the asset	organization's
				to protect some	of assets	responsibility	management	physical
				assets. The list	exists and is	matrix for the	process, so rows	assets (e.g.,
				of assigned	published.	protection of	in the matrix are	computers,
				responsibilities		individual assets.	created when new	printers,
				is not		Successive	assets are	media, etc.)
				documented.		versions of the	acquired. Assets
						matrix are	without a
						archived to help in	responsible party
						future	is immediately
						investigations.	flagged for
							corrective action.
		Security in job	No formally	Specific	Responsibility	A specific party is	Job descriptions	Interpretation
		definition and	defined	individuals are	for security	responsible for	and personnel	is based on
		resourcing	process.	aware of their	decision	developing job	screening	SSO/IRT
				responsibility.	making has	responsibilities,	arrangements are	type position.
					been assigned	personnel	periodically
					and	screening and	reviewed to
					documented.	confidentiality	conform to the
						agreements.	changing security
							needs of the
							business. Also
							personnel are
							required to sign
							and agree to
							confidentiality
							agreements.
		Information security	No formally	Key members	Training for	A specific party is	Security
		education and	defined	of personnel	personnel is	responsible for	curriculum is
		training	training plan	are trained on	defined and	defining the	periodically
				an ad-hoc	performed	training plan	reviewed to
				basis.	periodically.	developing	conform to the
						training schedules	changing needs
						for all personnel	of the business.
							Training records
							are reviewed
							against policy
							and exceptions
							lead to training
							program updates.
		Approval process	No approval	Informal,	A clear	A specific party is	The approval
		for the acquisition	process	undocumented	approval	responsible for	process is
		and installation of	exists.	knowledge of	process is	defining and	periodically
		IT facilities.		steps to be	defined for	maintaining the	reviewed to
				followed when	the	approval process	conform to the
				acquiring or	acquisition	for IT facility	changing needs
				installing IT	and	acquisition and	of the business.
				facilities exists.	installation of	installation.	The approval
					IT facilities		process for each
					and published		acquisition and
					across the		installation of IT
					enterprise.		facilities is
							reviewed for
							accuracy and
							corrective action
							is taken where
							appropriate.
IV.2	Security of	Security Control of	No control	Physical access	The access	Third-party access	The access logs
	Third Party	Third Party Access	mechanism	control allows	control rules	is linked to the rest	and the list of
	Access	to Information		ad hoc	are	of the	authorized third
		Processing Facilities		decisions by IT	documented.	organization's	parties is
				staff, who have	There is a	security system	regularly audited
				been told	formal	through the	and changes to
				informally	contract with	issuance of access	procedures is
				what to do.	each party	tokens, and	made when the
					that requires	accesses are	need arises.
					access.	logged.
IV.3	Outsourcing	Security Controls	None;	IT, Security,	The	There is a registry	Procedures are	Critical
		for External	contractors	Legal, or	procedures for	of contractors.	reviewed on at	applications
		Contractors	are handled	Purchasing	contractor	They sign the	least an annual	stay in house
			by task	apply some	security are	security policy,	basis for possible	Approval of
			owner	regular steps	documented	NODE and IP	improvements.	business
			without	when a	in writing and	agreements.		owners.
			specific	contract is	personnel and	Audits are run at		Implications
			policies or	issued. These	managers	least quarterly to		for business
			procedures.	steps are not	have access to	make sure the list		continuity
				specifically	them and are	of contractors is		plans.
				documented.	aware of their	current. The		Security
					contents.	owner of the		standards and
						process is defined.		compliance
								Security
								incident
								procedures.
V.1	Accountability	Coverage of Asset	No inventory	Manual	Inventory	Schedule, triggers,	There is a process	Information
	for Assets	Inventory		inventory,	performed	roles and	to review what	Asset
		Maintenance		occasional, on	according to	responsibly, are	happened after	Inventory
				demand.	written	defined.	each inventory.	Software
					procedures,	Ownership is clear	Inventories are	Asset
					but schedule	and known	incremental, not	Inventory
					and triggering	throughout the IT	from scratch	Physical
					events are not	organization and	every time. Asset	Asset
					well defined.	management.	inventories are	Inventory
					Typically not		automated.	Services
					automated.			Inventory
		Ease of Alteration	Information	There is	There is a	There are control	There is a	Printed
		of Information	assets can be	informal	documented	mechanisms (e.g.,	mechanism in	Reports
		Assets	altered	knowledge that	change	access controls) to	place to review	Screen
			without	classified	procedure that	prevent alteration	the effectiveness	Displays
			control	documents	applies to all	without proper	of the change	Magnetic
				cannot be	classified	authorization.	control process	Media
				altered at will,	information		and detect the	Electronic
				but no	assets. No		need for	Messages
				systematic	systematic		improvements.	File Transfers
				procedures.	control
					mechanisms
					in place.
		Coverage of	No	Covers some	There is an	Information	Information	Information
		Information	procedures in	information	Information	handling	handling training	Asset
		Handling	place for	assets. Little	Handling	procedures are	is part of written	Inventory
		Procedures	handling	formality. No	manual,	owned by	IT and Personnel	Software
			information.	regular	mentioned on	appropriate	procedures.	Asset
				reviews.	the public	functions including	Processes in	Inventory
				Applied by few	web page, and	IT but also	place to report	Physical
				business units.	covering	Finance, HR,	and learn from	Asset
					essentially all	Legal, etc.	cases when	Inventory
					types of assets	Organization	information has	Services
					and all	policies define the	been handled	Inventory
					business	roles and	incorrectly.	Printed
					units.	responsibilities in		Reports
						following		Screen
						procedures.		Displays
								Magnetic
								Media
								Electronic
								Messages
								File Transfers
								(“Handling” = copying,
								storage,
								electronic
								transmission,
								spoken
								transmission,
								destruction)
V.2	Information	Classification of	No	Ad hoc	Information	Ownership of the	Security	Printed
	Classification	Information Assets	classification	classification,	asset	classification is	classification is	Reports
		Labeling of		at document	classification	clearly defined as	reviewed	Engineering
		Information Assets		owner's	is published	part of company	periodically. List	files (photos,
				initiative.	and “pushed”	procedures and is	of documents	microfiche,
				Most	to all potential	known of	with highest	etc.)
				documents not	document	management.	classification is	Screen
				marked. If	owners. It		reviewed	Displays
				marked, labels	covers		periodically.	Magnetic
				are	security.		Declassification	Media
				inconsistent.	Classified		procedures exist.	Electronic
				No systematic	information is			Messages
				awareness	labeled,			File Transfers
				campaign.	consistently.
VI.1	Security in Job	Screening of	Incomplete	Screening of	Documented and	A specific party is	Procedures are	Applicant
	Definition and	new	or a lack of	applicants is	published	responsible for	reviewed regularly	refers to all
	Resourcing	applicants.	screening of	performed	procedures for	defining and	for improvements	employees
		Complete	applicants.	informally, is	applicant	maintaining the	and compliance.	(contractor,
		checking of	Contractor	not documented,	screening exist	screening procedure.	Security issues found	permanent,
		the new	hiring are	and is not	and are used by	Results of the	to be related to	or part time)
		applicant's	not vetted	performed	the organization.	screening are	failings in the
		CV.	through HR.	consistently.		captured in the	screening procedure
		Screening of				applicant's HR file.	mandate immediate
		contractor					review and update of
		and					the procedure.
		temporary
		staff
VI.2	User Training	Security	Little	Discussed with	Documented in	Roles and	Audits of the security
		awareness of	awareness of	employees and	writing and made	responsibilities to	acknowledgments are
		personnel	corporate	contract or	available to all	maintain and	performed. A system
			security.	temporary	staff. Employees	communicate the	of re-
				personnel upon	receive a copy of	security policy are	acknowledgment
				hiring.	security policy on	defined.	occurs periodically
					hiring and are	Acknowledgement	and upon changes to
					required to	of the policy is	the security policy.
					acknowledge	tracked and stored	Incidents are
					receipt.	as part of the HR	analyzed for
						policy of the	performance
						employee.	improvement to the
							security awareness
							procedures.
		Security	No education	Security	Security	A specific party is	Training plans are
		education	or training is	education and	education is	responsible for	periodically reviewed
		and technical	provided.	technical	documented and	defining and	to conform to the
		training		training are not	included as part	maintaining the	changing needs of the
				provided	of the hiring	security education	business. Training
				consistently and	process.	and technical	records are reviewed
				the	Technical	training program.	against policy and
				responsibility is	training roadmaps	Training records are	exceptions lead to
				at the discretion	exist for each	captured in the	corrective actions.
				of management.	employee.	employee's file.
						Review and
						planning for future
						training is part of
						the appraisal
						process.
VI.3	Responding to	Disciplinary	None	Managers have	The definition of	The documented	After each incident
	Security	Process for	documented.	intuitive	violations,	process includes	that causes the
	Incidents and	Company	Reaction is	awareness of	investigation	roles and	procedure to be
	Malfunctions	Security	ad hoc.	need, can quote	process, and list	responsibilities for	invoked, the process
		Violation		multiple levels	of applicable	each step, and a	is reviewed and,
				of penalty,	penalties is	clear workflow.	when applicable, the
				including but not	documented,		process is revised
				limited to firing.	distributed,		(including the
				Managers and	signed by the		training or the
				HR	appropriate		penalty clauses).
				independently	parties, and
				agree on how to	personnel has
				initiate and	been educated as
				conduct	to the content.
				disciplinary
				actions.
VII.1	Secure Areas	Protection	The IT	Access control is	List of secure	All access to secure	Auditing of access
		from	equipment is	provided on an	perimeters and	IT areas is	control system logs is
		unauthorized	left	ad hoc basis	access rights to	performed by a	done periodically.
		access.	unattended	typically by IT	those areas are	mechanism (e.g.,	Changes in facilities
		Physical	with no	manager. No	documented and	badge access control	and management
		entry control	controls	defined list of	published.	system) that allows	trigger a review and
		to office,	beyond	access rights is		for personal	revision of the access
		room.	physical	published or		identification and	procedures.
		Physical	building	managed.		auditing. Access
		security for	access.			control is managed
		IT facilities.				centrally for
						granting and
						revoking rights and
						is linked to hiring
						and termination
						policies.
VII.2	Equipment	Fire alarm	The fire	Procedures for	The fire alarm	Reaction to actual
	Security	system in not	alarm system	the fire alarm	system is tested.	alarms is reviewed
		present.	exists and	system are	Procedures exist	and improvements
			people have	visible and	for evaluation of	implemented into
			been	posted,	the fire alarm	the current system
			informally	including	system including	and alternative
			made aware	evacuation path,	damage	systems reviewed
			of the	behavioral	assessment and	where necessary.
			system.	actions, Halon	recovery,
				warnings, etc.	evacuation
					headcount, etc.
		Personal	No policies	Policies for	There is a	A specific party is	The personal
		workstation	for personal	personal	documented	responsible for	workstation policy is
		policy	workstations	workstations	policy for	defining and	regularly reviewed to
			exist.	exist but are not	personal	maintaining the	ensure it conforms to
				published or	workstations and	personal	the changing needs of
				adopted fully	steps are taken to	workstation	the business. Personal
				across the	spread its	policy.	workstation needs are
				organization.	awareness among	Sensitive	reviewed and changes
					employees.	information is	are made where
						protected by	necessary. Audits are
						means of	carried out to ensure
						encryption.	that the organization
							maintains a recognized
							workstation policy to
							ensure efficient
							management.
		Protection	There are no	There is an	There is a formal	A specific party is	The safety threat policy
		from	procedures	informal safety	documented	responsible for	is regularly reviewed to
		environmental	in place to	threat protection	policy in place. It	defining and	ensure it conforms with
		threats and	protect from	policy in place.	details all the	maintaining the	the changing needs of
		hazards.	safety threats	This is not	steps that need to	safety threat	the business. The
		Protection	or hazards.	enforced	be followed to	control guidelines.	policy is regularly
		from human		throughout the	protect from		reviewed and changes
		carelessness		organization and	potential hazards.		are made where
		(eating,		the details of the			necessary to ensure
		smoking,		policy are not			continued compliance.
		drinking).		documented.
		Protection
		from power
		and
		communication
		cabling
		from
		interception
		or damage.
VII.3	General Controls	Inspection of	Incoming	There is no	There is a	A responsible	The key goods
		incoming	goods are	formal process	documented	party is identified	screening process is
		goods for	not	to inspect	process whereby	to manage the	regularly reviewed to
		hazards	inspected.	incoming goods.	all incoming	processes and	ensure they conform to
				It is carried out	goods are	procedures for	the changing needs of
				in an ad	inspected per a	inspecting	the business. Goods
				hoc manner.	defined plan.	incoming goods	screening needs are
						for safety	reviewed and changes
						compliance.	are made where
							necessary. The
							organization maintains
							historical files of
							incoming goods; these
							are regularly reviewed
							to ensure that there are
							no discrepancies.
		Process of	There is no	An informal	A formal process	An inventory of	Audits of the
		removal of	standardized	process exists	is documented	organizational	organization's property
		organization's	procedure	for property	and published the	property is	are carried out
		property	for removal	removal.	to organization	maintained and	periodically and
			of property.		for property	updated regularly.	changes to the removal
					removal.	A group or	process are made
						individual is	where necessary.
						identified to verify
						that the process is
						followed.
		Equipment	There are no	Equipment	Equipment is	A responsible	Record of equipment
		maintenance	equipment	maintenance is	covered by	party is identified	maintenance is
			maintenance	carried out on an	insurance and the	to oversee	examined to determine
			policies and	ad hoc basis	equipment	equipment	fault patterns or abuses.
			the	based on	maintenance	maintenance	Appropriate changes
			equipment	manufacturer	controls the	policies are	are incorporated into
			maintenance	recommended	determination of	followed.	the maintenance
			is done only	service intervals	risk.		policies.
			on failure.
		Sensitive	Data	Data disposal	Data disposal	A responsible	The disposal procedure
		data disposal	disposal	procedure is	procedure is	party is identified	is audited regularly and
		procedure	procedure is	informally	formally defined	to oversee that the	appropriate steps
			not defined.	defined.	and published to	disposal procedure	incorporated into the
					the organization.	is followed.	procedure.
VIII.1	Operational	Management	None - each	Common	Documented in	Roles and	Procedures include a	Reporting
	Procedures and	Responsibilities	incident is	awareness of	writing and made	responsibilities are	mechanism to evolve	procedures
	Responsibilities	and	handled ad	procedures	available to all IT	defined.	them. Incidents are	cover:
		Procedures	hoc on a best	Effort for	staff (and other	Escalation and	analyzed to suggest	All types of
		Incident	effort basis.	repeatability	department staff	reporting chains	improvements. There	security
		Reporting		includes staff	with IT roles)	exist. Issues and	is a quality	incident
		Procedures		meetings,		requests are	improvement process,	Contingency
				training		recorded as	documented and	plans
				sessions,		trouble tickets.	applied.	Audit trails
				coaching				and similar
								Recover
								actions and
								authority
VIII.2	System Planning	Testing of	None; new	Testing is	A formal	The responsibility	Policy is	Includes issues
	and Acceptance	new	systems are	informal and is	document	to define, review,	periodically	of capacity
		information	placed in	performed based	defining the	and ensure	reviewed and	planning and
		systems	operation	on individuals'	testing and	compliance with	revised upon any	Systems
		requirements	without any	knowledge, not	deployment of	the testing policy	change in the	Acceptance.
		and upgrades	formal test	on a formal	new and	is defined. There	production systems	Issues to be
		prior to	procedure.	process.	upgraded systems	are system level	or organizational	considered
		deployment			is defined.	tools that prevent	structure. Testing	include:
						unauthorized	methodology and	Performance
						changes to	tools are	and Computer
						production	continuously	Capacity
						systems.	examined to	Requirements
						Documents exist	determine	Error Recovery
						detailing	applicability to the	and Restart
						interfaces into the	organization and	Procedures
						change	then introduced.	Security
						management		Controls/Issues
						process.		Manual
								Processes
								Business
								Continuity
								Arrangements
								Additional
								Load on
								existing
								machines
								Training in the
								operation of the
								new equipment
VIII.3	Protection	Detection and	No	IT staff has	A formal,	A specific party is	The procedure	Procedures
	Against	protection	detection,	informally	documented	responsible for	includes a	cover:
	Malicious	against	protection	defined	procedure for	defining and	mechanism for	All types of
	Software	malicious	measures,	procedures for	detecting and	maintaining the	evolution. Incidents	virus and
		software.	reporting,	detecting and	handling	detection and	are analyzed to	malicious
		User	or recovery	handling	malicious	protection	suggest	software
		awareness of	procedures	malicious	software and	procedures,	improvements. The	incident
		procedures to	exist, and	software and	virus attacks	informing and	toolset is	Contingency
		deal with	dealing	virus attacks.	exists and is	training the users,	continuously	plans
		malicious	with	There are no	communicated to	managing the	examined and	Audit trails and
		software	malicious	common tools,	all employees as	detection and	updated to provide	similar
		Procedures	software	formal	part of the	recovery efforts,	maximum protection	Recover actions
		for reporting	and virus	documentation,	corporate security	and selecting and	against changing	and authority
		and recovery	attacks is	or training	policy. A	maintaining the	treats.
		from virus	entirely	programs for all	standard set of	protective tools.
		attacks	reactive	employees.	protective tools is
			and		defined and
			handled in		deployed.
			an ad hoc		Training is given
			manner.		to all employees.
		Policy	No policy	Software	A software	A specific party is	List of authorized
		relating to	or	monitoring	licensing policy	responsible for	software is
		licensed	monitoring	policies are	is documented	monitoring and	periodically
		software and	exists	informal and	and published to	maintaining	reviewed to conform
		prohibition of	regarding	performed on an	all employees.	authorized	to the changing
		unauthorized	software	ad hoc basis. The		software licenses	needs of the
		software	installation.	IT organization,		for the enterprise.	business. Software
				when involved in		A software	audits are reviewed
				software		inventory	and exceptions lead
				procurement,		licensing tool is	to corrective actions.
				applies controls		used to monitor
				informally.		and ensure
						compliance.
VIII.4	Housekeeping	Monitoring of	No	Informal	Capacity plan and	Ownership of the	New technology,
		processing	monitoring	monitoring as	capacity	capacity plan and	contractual
		power and	exists.	part of system	management	capacity	agreements, and
		storage to	Capacity	management	process covering	management	supplier selection
		ensure	adjustments	procedures	processing	process is defined.	are continuously
		availability	are	performed on an	power, memory,	Formal	researched and
			performed	as needed basis.	disc space,	mechanism for	introduced into the
			in reaction	No management	LAN/WAN	business managers	environment in
			to	capacity plan or	capacity, backup	to place	order to provide the
			problems.	model is	capacity, number	requirements into	necessary resources
				specifically	of user	the plan and a link	while optimizing the
				defined.	workstations,	exists between the	costs.
					physical space	capacity planning
					and power.	process and the
						budgeting process.
VIII.5	Network	Covered by other
	Management	questions in this section
VIII.6	Media Handling	Procedures	No	IT staff has	Formal,	A specific party is	Procedures are	Media includes:
	and Security	and controls	procedures	informally	documented	responsible for	periodically	IT computer
		to protect	or controls	defined	procedures for	defining and	reviewed to address	room media
		computer	are in place	procedures and	protecting	maintaining the	changes in the type	(e.g., backup
		media	to protect	controls for	computer media	procedures for the	or volume of	tapes,
			computer	protecting	exist and are	access control	computer media to	removable hard
			media.	computer media.	communicated to	systems and	be handled. Audit	drives, CD-
				There is no	all employees as	auditing of access	logs are reviewed	ROMs, etc.)
				formal	part of the	to computer	and exceptions lead	User media
				documentation,	corporate security	media.	to corrective action.	(e.g., CD-
				access logs, or	policy. Controls			ROMs, floppy
				training programs	are in place to			discs, etc.)
				for all employees.	limit and track
					access to media.
					Training is given
					to all employees.
VIII.7	Exchanges of	Security of	No defined	No corporate	A corporate	A specific party is	The standards are	Standards for
	Information and	exchange of	procedures	standard or policy	standard for the	responsible for	periodically	secure
	Software	data and	to secure	exists addressing	security exchange	defining and	reviewed to address	exchange of
		software with	the	securing the	of data and	maintaining the	changes to the data	data and
		other	exchange	exchange of data	software with	standards for the	being exchanged or	software with
		organizations.	of data or	and software with	other	secure exchange	the means of	3rd parties and
			software.	other	organizations is	of data and	exchanging. The	outsourcing
				organizations.	documented and	software. An	information	vendors.
					published to all	information	classification policy	Information
					employees.	classification	continually evolves.	classification
						policy determines		policy
						what can be and
						how it is
						transmitted.
IX.1	Business	Documentation	No	An informal,	An access policy	A specific party is	The access policy	Access rights
	Requirements	of business	awareness	undocumented	statement	responsible for	statement is	encompasses
	for Access	requirements	or practice	access control	defining access	defining and	periodically	accounts for
	Control	for access	of access	practice is	rights of each	maintaining the	reviewed to conform	network,
		control.	control.	applied on an ad	user or group of	access policy	to the changing	operating
		Access policy		hoc basis.	users exists and is	statement and	needs of the	system, and
		statement			published.	ensuring it is in	business. Security	application
		defining the				alignment with	incidents are	access.
		access right of				business	reviewed and	ACLs, user and
		each user or				requirements.	modifications to the	system
		group of users.					access policy	accounts, etc.
		Protection of					statement are made	Automatic
		connected					where appropriate.	identification of
		services from						terminals and
		unauthorized						portable
		use.						devices.
		Review of user						Timeout of
		access right						remote systems
		and						left unattended
		capabilities						for extended
		Policy						periods of time
		concerning the
		use of network
		and network
		services.
		Network
		controls in
		place
IX.2	User Access	System of	No	An informal,	A user account	A specific party is	The user account	Deletion vs.
	Management	formal	control	undocumented	policy defining	responsible for	policy is	disabling
		registration/de-	over	user account	access rights,	defining and	periodically	accounts.
		registration for	access to	practice is	privilege levels,	maintaining the	reviewed to conform	Unique id for
		access to IT	IT	applied on an ad	and	user account	to the changing	all users.
		services.	services.	hoc basis.	creation/deletion	policy. User	needs of the
		Immediate			rules exists and is	account	business. Audit
		account			published.	creation/deletion	requirements are
		removal for				records are	reviewed and
		users who				archived.	modifications to the
		change duties					user account policy
		or leave the					are made where
		company.					appropriate.
		User's					Multiple accounts
		privilege in					per individual are
		overriding					created or deleted
		system/application					through a single
		restriction.					point of control.
		Record kept of
		all privileges
		allocated.
		System routine
		to grant
		privilege to
		users.
		Access control
		to program
		source library
IX.3	User	Security of user	Passwords	An informal,	A published	A specific party	The password policy is	Limit the number
	Responsibilities	password. User	are not	undocumented	password	is responsible	periodically reviewed	of password
		password	used.	password	policy defines	for defining and	to conform to the	attempt before
		confidentiality		practice is	password	maintaining the	changing needs of the	the system locks
		level		applied on an	strength (e.g.,	password policy.	business. Periodic	out the user.
				ad hoc basis.	length,	Record of	audits (cracking) of	Record and make
					inclusion of	password	passwords are	user aware of
					special	histories is	performed to ensure	unsuccessful
					characters),	archived.	compliance and	logon attempts
					aging, and		exceptions are noted,	Enforcement of
					usage.		documented, and	password rules
							corrective action is
							taken.
		Good-practice	No	An informal,	A good-practice	A specific party	A process exists to	No display of
		guidelines to	guidelines	undocumented	guidelines	is responsible	solicit suggestions for	system identifiers
		users in	exist.	guidelines is	statement is	for defining and	best-practice guidelines	until logon has
		ensuring good		provided to	defined and	maintaining the	from internal and	been successful
		security.		users on an ad	incorporated	good-practice	external sources and to	General notice
				hoc basis.	into user	guidelines.	incorporate them into	warning that the
					training		the organization's user	system should
					programs.		security guidelines.	only be used by
								authorized users
								If error occurs at
								logon do not
								indicate what the
								error was
		Cryptographic	No	An informal,	A good-practice	A specific party	A process exists to
		Controls	guidelines	undocumented	guidelines	is responsible	solicit suggestions for
			exist.	guidelines is	statement is	for defining and	best-practice guidelines
				provided to	defined and	maintaining the	from internal and
				users on an ad	incorporated	good-practice	external sources and to
				hoc basis.	into user	guidelines.	incorporate them into
					training		the organization's user
					programs. The		security guidelines.
					guidelines
					cover:
					encryption,
					digital
					signatures, key
					management,
					non-repudiation
					services
IX.4	Network	Covered in other area in this
	Access Control	section
IX.5	Operating	Covered in other area in this
	System Access	section
	Control
IX.6	Application	Covered in other area in this
	Access Control	section
IX.7	Monitoring	Covered in other area in this
	System Access	section
	and Use
IX.8	Mobile	Mobile	No	An informal,	A good-practice	A specific party	A process exists to	Laptop, Mobile,
	Computing and	Computing and	guidelines	undocumented	guidelines	is responsible	solicit suggestions for	and Palmtop
	Teleworking	Teleworking	exist.	guidelines is	statement is	for defining and	best-practice guidelines	security to ensure
				provided to	defined and	maintaining the	from internal and	company
				users on an ad	incorporated	good-practice	external sources and to	information is not
				hoc basis.	into user	guidelines.	incorporate them into	compromised.
					training		the organisation's user
					programs.		security guidelines.
X.1	Security	Risk	There is no	An informal	A published	A specific party	The risk assessment
	Requirements	assessment and	framework	undocumented	risk assessment	is responsible	and risk management
	of Systems	risk	or risk	risk	and risk	for defining and	policies are
		management	assessment.	assessment	management	maintaining the	periodically reviewed
		used for		and risk	procedure	risk assessment	to conform to the
		analyzing		management	exists.	and risk	changing needs of the
		security		practice is		management	business. Changes are
		requirement		applied on an		guidelines.	made to the policy
				ad-hoc basis.		An archive is	where required.
						kept of the risks
						identified and
						the action taken
						to manage the
						risk.
		Safety check	No safety	An informal	There is a	A specific party	The safety checks are
		while procuring	checks are	procedure	documented	is responsible	regularly reviewed to
		new program	carried out	exists whereby	procedure that	for defining and	ensure that they
		and software	when	new programs	is followed	maintaining the	conform to the
			procuring	and software	before any	software safety	changing needs of the
			new	are assessed	software is	check	business. There is a
			software.	before being	purchased.	guidelines.	regular risk analysis is
				put in to the	This ensures	Modifications to	carried out to ensure
				operational	that all software	vendor supplied	safety of existing
				environment.	purchased	packages are	systems and
				This task in	conforms to	made to comply	compromise to their
				performed on	company	with system	security is controlled.
				an ad-hoc	security	requirements	Emphasis is given on
				basis.	guidelines.	and vendor	quality certification of
						consent is	new products.
						obtained before
						doing so.
X.2	Security in	Validation	There is no	An informal	There is a	A specific party	The validation control
	Application	control while	validation	process exists	published	is responsible	procedure is regularly
	Systems	data input to	of	where data is	standard which	for defining and	reviewed to ensure that
		application	information	both verified	describes the	maintaining the	they conform to the
		system	on	before it is	validation tests	validation	changing needs of the
		Data validation	application	entered in to	that are	control	business. Periodic
		of stored	systems.	applications	performed.	guidelines.	audits are performed of
		information		and existing	There is a		data on application
		Output Data		data is	documented		systems to ensure
		Validation		verified. Basic	process which		compliance.
				tests like	is followed.		Exceptions are noted,
				missing or			documented and
				incomplete			corrective action is
				data, invalid			taken.
				characters in
				fields are
				performed on
				an ad-hoc
				basis.
X.3	Cryptographic	Cryptographic	There are	There is an	There is a	A specific party	The cryptographic
	Controls	control	no	informal	documented	is responsible	controls are regularly
			cryptographic	practice	procedure	for defining and	reviewed to ensure that
			controls	employed	which defines	maintaining the	they conform to the
			or existing	whereby some	the steps which	cryptography	changing needs of the
			system	files are	outlines which	control	business. Audits are
			architecture	encrypted.	document	guidelines.	carried regularly to
			does not	This is done at	classifications	Separate key	ensure that information
			support	the user	need to be	management	that should be
			cryptography.	discretion and	encrypted and	procedures are	encrypted is kept
				on an ad-hoc	the process to	used for digital	encrypted and that the
				basis.	be followed to	signatures and	encryption method
					achieve this.	encryption.	used is adequate.
		Vulnerabilities	There are	There is a	There is a	A specific party	The key management
		of	no key	process in	documented	is responsible	system is regularly
		cryptographic	management	place where by	key	for defining and	reviewed to ensure
		keys.	procedures.	suitable key	management	maintaining the	they conform to the
		Key		management	system which	key management	changing needs of the
		management		exists, based	defines the	system.	business. Key
		system.		upon an	steps to be	Separate key	management needs are
		Documentation		informal set of	followed. This	management	reviewed and changes
		of key		standards,	ensures that the	procedures are	are made where
		management		procedures and	type of	used for digital	necessary. Audits are
		system		secure	algorithm and	signatures and	carried out to ensure
		(activation &		methods.	length of keys	encryption.	that the organization
		de-activation			are considered	Cryptographic	maintains a recognized
		date, certificate			to identify level	keys have	certification authority
		information)			of	defined	to ensure key
					cryptographic	activation and	protection and efficient
					protection	deactivation	key management.
						dates. All keys
						are protected
						against
						modification and
						destruction in
						case of private
						key
						compromise.
X.4	Security of	Protection and	No change	An informal	There is a	A specific party	The change control
	System Files	control of	control	procedure	documented	is responsible	policy is regularly
		system test	procedure	exists for	standard	for defining and	reviewed to ensure
		data.	in place and	change	available to	maintaining the	that it conforms to
		Change control	no	control. This	employs	change control	the changing needs
		procedure	provisions	task is	describing the	guidelines.	of the business.
		Control of	for the	performed on	procedures to	Version control	Version control
		operational	protection	an ad-hoc	follow to ensure	for software	logs are audited and
		software	of system	basis.	that the change	update is	any exceptions are
			test data.		control	maintained and	documented, noted
					procedures are	archives are kept	and corrective
					followed	of all versions.	action is taken if
					correctly		necessary.
X.5	Security in	Awareness of	There is no	An informal	There is a	A specific party	The software	The new software is
	Development	software	process in	procedure	documented	is responsible	update policy is	put in a test
	and Support	upgrade to	place to	exists to	standard	for defining and	regularly reviewed	environment to check
	Processes	enhance the	monitor	monitor	available to	maintaining the	to ensure that it	for anomalies with
		security level	security risk	vendor web	employees	software update	conforms to the	security policies
			posed by	sites to obtain	describing the	guidelines. An	changing needs of	before
			software	software	procedures to	archive is kept	the business.	implementation
			installed on	updates. This	follow to ensure	of all software	Periodic audits are
			machines.	task is	that all software	upgrades.	performed of
			Software	performed on	installed on	Change control	software upgrades
			upgrade	an ad-hoc	their machines	procedures and	to ensure
			does not	basis.	is of the latest	contractual	compliance.
			take into	Security issues	version.	agreements exist	Exceptions are
			account the	defined by the	All security	to escalate	noted, documented
			security of	vendors are	issues with the	security issues to	and corrective
			the new	only	new release	appropriate	action is taken if
			releases	considered.	specific to	levels and	necessary.
					organizational	remedy them.
					system platform
					are identified
					and confirmed
					with the
					vendor.
XI.1	Aspects of	Contents of	No plan.	There is some	There is a	Employees are	Includes process	Risk analysis of critical
	Business	Business		knowledge of	written and	trained, and	for improvement	business processes.
	Continuity	Continuity		what to do in	properly	training is	after each	Identifies events that
	Management	Process		case of disaster	distributed plan.	periodically	invocation.	can cause interruptions
		Procedures and		(e.g., based on	Process	refreshed.		to business processes,
		Schedules		training or on	includes:	Plan includes		and includes assessment
		Included in the		prior	Fallback	alternate		of the impact of those
		Process		experience)	procedures	communication		interruptions.
				but no	Resumption	methods if
				documented	procedures	communication
				process.	Maintenance	is severely
					schedules	affected.
						Process also
						includes:
						Assignment of
						responsibilities
						Conditions for
						activation
		Development of	Plan does	A set of	There is a	The	The process is	Business continuity
		Business	not exist.	measures can	written business	management	reviewed in case	process covers events
		Continuity	Some	be applied in	continuity	chain	of change in	that are specific to the
		Process	awareness	case of a	process that	responsible for	system, staff,	local environment (i.e.,
		Testing of	of measures	business	includes risks,	executing the	disaster recovery	flood, power outage,
		Business	that can be	interruption.	events, roles	business	contractor or	political unrest, fire,
		Continuity	taken in	They do not	and	continuity	contract,	hurricane, earthquakes,
		Process	case of a	constitute	responsibilities,	process is	business,	etc.) and business needs
		Review and	business	formal,	technical	define, and all	application,	(i.e., credit card center
		Update of	interruption.	defined,	measures,	managers and	locations, or	cannot be down more
		Continuity	Actions	published, or	reporting, and	staff know what	legislation.	than a few minutes)
		Process	would occur	managed plan.	communication.	the chain is.	Post-mortem
		Reasons that	in an ad hoc		The plan has	Testing occurs at	reviews after
		Cause Review	manner.		been tested at	least annually	execution with
		of the Plan			least once.	and maintains	documented
						the business	improvement
						continuity	actions.
						process.
XII.1	Compliance	Restrictions in	No	Ad hoc	Systematic	Clear	Periodic review	Copyright policy
	with Legal	Place on the	restrictions	restriction on	restrictions,	responsibility to	of the policy for	Acquisition procedures
	Requirements	Use of	in place.	some	documented,	enforce the	continuing	Copyright awareness
		Materials for		documents	based on the	restrictions.	improvement.	information
		Which There		only.	information	Training is	Periodic review	Maintenance of licenses
		May Be			classification	provided.	of the	Check on software
		Intellectual				Employees are	restrictions to	held/used
		Property Rights				aware.	make sure	Policy on software
							they're	disposal
							appropriate.	Compliance with
								licenses
		Safeguards	No	Some	Clear	Safeguards in	Periodic review	Personnel information
		against loss,	safeguards	organizational	responsibilities	place covering	of systems in	Copyright information
		destruction or	employed.	data backed up	to ensure that	all	place and	Company confidential
		falsification of	No defined	and secured.	organization	organizational	security of	information
		organizational	hierarchy as	Backups may	records are not	records.	systems that deal	Public web sites
		records	to whom	be kept onsite.	compromised.	Training	with
			has access	No logs kept	Some user	provided to	organizational
			to what	of user	activity is	educate users.	records. Each
			information.	activity.	logged.	Management	incident is
					Organizational	responsibly to	subject to a post
					data is kept	ensure that	mortem
					securely.	records are kept	procedure that
					Documents are	accurate and	includes a
					publicly	secure. Access	review of
					available that	rights and	whether
					describe the	privileges in	applicable
					policy and	place to restrict	policies were
					procedures that	access to certain	correctly
					employees	organizational	communicated.
					should follow	records. Web	Users are taught
					to maintain	sites protected	the incident
					integrity and	from	reporting
					safety of	defacement.	procedures. Full
					organizational	Critical files	audit logs
					records.	identified and	maintained with
						protected against	system
						falsification by	start/finish
						CRC checks,	times, system
						etc.	errors and
							corrective action
							and name of
							person making
							alterations to the
							information.
		Compliance	Knowledge	Data	Legislation is	Processes and	There is a
		with data	of	protection	applied and	procedures are	regular process
		protection	legislation	legislation is	Data protection	put in to place	in place to
		legislation	is limited to	discussed with	legislation is	for monitoring	review changes
			specific	employees and	made available	to ensure that the	in legislation, or
			people or	contract or	to employees in	company is	new needs of the
			departments	temporary	a centralized	continually	business.
			(HR, Legal,	personnel	location.	compliant. The	Training is
			etc.) and is	upon hiring	Impact of	responsibility to	provided to
			not	into specific	legislation and	do so is clearly	users to ensure
			documented.	departments.	concerned data	assigned.	the continued
					has been		compliance with
					written up and		legislation. The
					made available		process and
					to employees.		responsibility to
					All affected		receive,
					processes		investigate and
					include		correct any
					appropriate		reported
					protection		exception is
					steps.		defined.
		Compliance of	No	Standards and	Standards and	A clearly	There is a regular	Intellectual Property
		information	published	codes of	codes of	designated	process in place to	Rights
		systems with	codes of	practice are	practice are	person or body	review changes in	Copyright
		published	practice and	generally	defined and	has	published standards	Data Protection Act
		standards or	no	understood but	published	responsibility for	or codes of
		codes of	awareness	are applied	internally and	the reviewing,	practice. Findings
		practice		inconsistently	are made	maintaining, and	of non-compliance
				through the	available to	training users on	result in corrective
				organization.	employees in a	the published	action.
					centralized	standards or
					location.	codes of
						practice.
XII.2	Reviews of	Documentation	No	Some	Documents are	Responsibilities	Documents are	Laws on protection
	Security Policy	of regulatory	documentation	documentation	made publicly	are assigned to	created as soon as	and/or correction of
	and Technical	and contractual	exists.	exists although	available on the	individuals to	there is a change in	personal information
	Compliance	requirements		it does not	corporate web	produce	the contractual or	(employees and/or
		for each		cover all	site or on a	documents as	regulatory	clients, suppliers,
		information		details of	public notice	soon as a new	requirements of the	etc.)
		system		regulatory/contractual	board. Full	system is	project.	Procedures for
				requirements	documentation	sourced.	Documentation is	disclosure to proper
				for each IS.	exists for	Templates exist	available to	authorities.
				There is no	contractual and	for the creation	personnel with	ISO 9000
				standard	regulatory	of documents	correct clearance.	requirements
				document	requirements	and there is a	Periodic inventory	Regulatory agencies
				template used,	for all	central	of information	(e.g., FDA or FCC in
				documents are	information	repository where	systems includes	the United States)
				created as and	systems in the	they are stored.	checks that
				when required	organization.	The templates	compliance
				by individual		have designated	requirements exist.
				employees.		owners.	Exceptions trigger
				There is no			a well-defined
				central data			process to review
				store for the			procedures in order
				documents			to eliminate this
				(need to ask			risk.
				people who
				know).
XII.3	System Audit	Control Against	No controls	Terms of use	Terms of use of	The	Periodic reviews of
	Considerations	Computer	or	of computer	organizations	responsibility of	who is authorized
		Misuse	safeguards	equipment are	computer	managers is	to do what.
		Safeguard of	in place	discussed with	equipment are	defined. Tools	Information
		Audit Tools to		employees and	available from a	employed to	gathered from
		Prevent Misuse		contract or	centralized	monitor usage of	monitoring tools is
				temporary	location	computer	used to make
				personnel	(Intranet site,	equipment.	decisions for future
				upon hiring.	office notice	Staff has well	policy.
					boards, etc)	defined roles	There is an incident
						and access rights	review procedure.
						to computer file	Periodic “white
						systems.	hat” intrusion
						Personnel are	attempts are made
						made aware that	and followed by
						their computer	corrective actions.
						related activities
						are being
						monitored, and
						to what extent.
		Review/Audit	No process	Occasionally	Reviewed at	A clearly	There is a defined
		of information	is in place	reviewed or	intervals, but no	designated	mechanism to
		systems to		audited if	clear	person or body	review and upgrade
		ensure they are		senior	management	has	the policy after
		in compliance		management,	responsibility to	responsibility for	every security
		with security		auditors, etc.,	trigger reviews	the process, and	incident (Is
		policies and		ask	of exploit	reviews it	anything missing
		standards			results	regularly.	from the policy that
							could have
							prevented the
							problem?)
		Coverage of	No	Few	Clear	Audit tools are	Safeguards in place
		System Regime	coverage	safeguards in	responsibilities	only available	covering all audit
		(event logging)	exists.	place. Audit	to ensure that	for use by key	tools. Periodic
				tools are not	audit tools are	personnel.	review of systems
				managed	not misused.	Access rights	in place and
				securely and	Training	and privileges	security of systems
				user access is	provided to	are enforced to	that audit systems.
				not monitored.	educate users.	maintain	Users are educated
						security.	on the importance
							of safeguarding
							their audit tools.
		Compliance of	No	Standards and	Standards and	A clearly	There is a regular	Intellectual Property
		information	published	codes of	codes of	designated	process in place to	Rights
		systems with	codes of	practice are	practice are	person or body	review changes in	Copyright
		published	practice and	generally	defined and	has	published standards	Data Protection Act
		standards or	no	understood but	published	responsibility for	or codes of
		codes of	awareness	are applied	internally and	the reviewing,	practice. Findings
		practice		inconsistently	are made	maintaining, and	of non-compliance
				through the	available to	training users on	result in corrective
				organization.	employees in a	the published	action.
					centralized	standards or
					location.	codes of
						practice.

Referring to the Security Assessment Matrix shown in Table 1, to perform the assessment for a given item, the assessment entity need only perform the following steps: (i) find the item in question, first by category then by sub-category; (ii) read the descriptions under each maturity level and determine if requirements of that maturity level are met; and (iii) record the highest maturity level for that item that is met by the organization's current information security policies and practices.

Once the preliminary rating has been completed, it may be displayed in a graphical manner. In one embodiment of the invention, the preliminary rating is displayed using a Security Maturity Assessment Reporting Tool (SMART). SMART allows the preliminary rating to be shown at a detailed level, i.e., all 61 elements are shown, or at a summary level, i.e., only 10 broad categories are shown. Further, SMART allows the organization to compare the preliminary rating to a predefined goal, an industry average, or to a prior assessment. Additionally, the layout of the SMART report allows an organization to readily identify areas that require improvement.

FIG. 3 illustrates a portion of a SMART report in accordance with one or more embodiments of the invention. A first column (10) lists the broad categories. A second column (12) lists the items within each of the categories. A third column (14) graphically represents the “assessed capability maturity” (ACM) (16). The third column is sub-divided into five levels (L1, L2, L3, L4, and L5) corresponding to the maturity levels listed above. For each item, the ACM is represented by shading the corresponding row up to the appropriate level. If the ACM is not at a goal (18), i.e., the level at which the organization wishes to be for the particular item, then an additional shading representing a gap (20) between the goal (18) and the ACM (16) is present.

For example, in FIG. 3, Category 2 contains four items: Item D (2), Item E (4), Item F (6), and Item G (8). Specifically, looking at Item G (8), the ACM (16) is at level 2 (22), while the goal (18) is at level 3 (24). Thus, a gap (20) is present between level 2 (22) and level 3 (24) on the row containing Item G (8). Thus, the organization can readily see that Item & (8) is below the goal (18). By contrast, the organization can also readily see that capability maturity level for Item F (6) is at the goal (26) set for this item, so there is no gap relative to Item F (6).

Returning back to the SMA phase, once the preliminary rating has been completed, the assessment entity reviews the preliminary rating with the organization. During the review, the preliminary rating may be revised, if necessary. Once this has been completed, a final rating is generated.

During the corrective action plan (CAP) phase, the CAP is generated using the final rating and the Security Assessment Matrix. The proposed actions are aimed at improving the items that have gaps and bringing the items up to the goal. Additionally, items in the CAP may also be prioritized according to the needs and resources of the organization. During the corrective action plan execution phase, the CAP is executed. For example, if the SAM states that for a certain item to be at Level 3, “the policy is written down,” and to be at Level 4, “there is an assigned manager in charge of applying this policy,” then it follows that if an organization is assessed at Level 3 for this item, and its goal is to be at Level 4, then the CAP should include the following action: “Put a manager in charge of this policy.”

The monitoring phase of the SMA includes periodic SMART reports to ensure that goals are met and maintained. Further, during this phase, the assessment entity may detect change in the environment that might require additions or changes to the security practices and/or policies. Additionally, during the monitoring phase, the assessment entity may provide assistance for debriefing the organization in the event of an information security incident. In one or more embodiments of the invention, the monitoring phase is optional.

FIG. 4 illustrates a flowchart detailing the SMA method in accordance with another embodiment of the invention. Initially, the organization's business goals are determined (Step 112), as well as the associated risk in terms of information security (Step 114). Written documentation is then collected about the organization's existing information security policies and practices (Step 116). Additional information is then collected via interviews (Step 118). Using the information gathered in Steps 112 through 118, the SAM rating is generated (Step 120). If additional information is obtained (Step 122), then step 120 may be repeated. If no additional information is obtained (Step 122), then a list of corrective actions is proposed (Step 124). The corrective actions are subsequently prioritized (Step 126) and executed (Step 128) to generate modified information security policies and procedures. The modified information security policies and procedures are then monitored (Step 130). If there is a change in the information security environment, e.g.) a first organization merges with a second organization resulting in the first organization's network being integrated into the second organization's network, or if the time for a periodic review arrives (Step 132), then the process proceeds back to Step 116.

The invention, in one or more embodiments, may have one or more of the following advantages. The SMA method is a systematic approach that includes a process, a detailed method for assessment (i.e., SAM), and a reporting tool (i.e., SMART). Further, the SMA method covers all aspects of information security and explicitly defines what each level means for each item. Further, the SMA method is action oriented. Further, each item is assessed as a capability maturity rather than pass/fail, allowing an organization to readily gauge where the organization is with respect to a particular information security item and to measure progress over time or against a goal, even if that progress is gradual. Additionally, the security assessment matrix may be used as a list of recommendations to detail how the organization may attain its information security goals.

Further, the SMA method is easy to apply, as each item and corresponding set of criteria for each maturity level associated with the item are clearly defined. Further, the SMA method is flexible, as it may be used for multiple purposes. For example, the SMA may be used for the purpose of establishing to a customer or regulatory authority that an organization has the required capability to perform a certain task. The SMA may also be used for the purpose of internally monitoring, over time, improvements decided by the organization's management. The SMA may also be used for the purpose of meeting a certain industry standard or reaching a goal established through analysis of the competition's security capabilities.

Further, the invention produces an objective rating of an organization's information security practices and policies removing the subjective element of the assessment process.

While the invention has been described with respect to a limited number of embodiments, those skilled in the art, having benefit of this disclosure, will appreciate that other embodiments can be devised which do not depart from the scope of the invention as disclosed herein. Accordingly, the scope of the invention should be limited only by the attached claims.