"Industry Best Practices" For Cybersecurity & Privacy Documentation
The development of cybersecurity and privacy documentation provides evidence of due diligence and due care through defining administrative, technical and physical requirements. Implementing consistent cybersecurity & data protection documentation helps your organization comply with current and evolving statutory, regulatory and contractual obligations associated with protecting the confidentiality, integrity, availability and safety of data and technology assets.
We offer a wide-assortment of cybersecurity policies, standards, procedures and more, since we understand that businesses have unique needs that cannot be met by just one product. While companies want to align with a single cybersecurity framework such as NIST 800-53, ISO 27002 or NIST Cybersecurity Framework, it is getting much more common for companies to have to juggle multiple frameworks and that requires scalable documentation.
Concise & Clear Cybersecurity & Privacy Documentation That Is Based On "Industry Best Practices"
Effective cybersecurity and data protection is a team effort involving the participation and support of every user that interacts with your company’s data and/or systems, it is a necessity for your company’s cybersecurity & data protection requirements to be made available to all users in a format that they can understand. That means your company must publish those requirements in some manner, generally in either PDF format or published to an internal document management tool (e.g., GRC/IRM, SharePoint, wiki, etc.). Regardless of the format in which you deliver your documentation to end users, our goal is to make that process as efficient, cost-effective and scalable, as possible.
We Know How To Write Cybersecurity & Privacy Documentation - Scalable, Comprehensive & Efficient
We leverage the Hierarchical Cybersecurity Governance Framework to take a comprehensive view towards the necessary documentation components that are key to being able to demonstrate evidence of due diligence and due care. This framework addresses the interconnectivity of policies, control objectives, standards, guidelines, controls, risks, procedures & metrics. This approach works well with any cybersecurity framework to help any organization, regardless of industry, to get and stay both secure and compliant.
ComplianceForge has simplified the concept of the hierarchical nature of cybersecurity and privacy documentation in the following downloadable diagram that demonstrates the unique nature of each documentation component that is expected to exist as part of a cybersecurity and privacy program. You can click on the image below to better understand how we write our documentation to link from policies all the way down to metrics.
Establishing Context For Cybersecurity & Privacy Documentation
Your cybersecurity & data protection documentation is meant to address the “who, what, when, how & why” across the strategic, operational and tactical needs of your organization:
The development and implementation of the policies and standards is evidence of due diligence that the organization's compliance obligations are designed to address applicable administrative, technical and physical security controls. It is important to ensure that policies and standards document what the organization is doing, as the policies and standards are often the mechanisms by which outside regulators measure implementation and maturity of the control.
The purpose of a organization's cybersecurity & privacy documentation is to prescribe a comprehensive framework for:
- Creating a clearly articulated approach to how your company handles cybersecurity – in terms of ISO 27001, this concept would be considered an Information Security Management System (ISMS).
- Protecting the confidentiality, integrity, availability and safety of data and systems on your network.
- Providing guidance to help ensure the effectiveness of cybersecurity and data protection controls that are put in place to support your company’s operations.
- Helping your users to recognize the highly-networked nature of the current computing environment to provide effective company-wide management and oversight of those related cybersecurity risks.
The objective is to provide management direction and implement necessary cybersecurity and data protections in accordance with business requirements and relevant laws and regulations.
Cybersecurity & Privacy Documentation - Editable, Scalable & Affordable
While policies and standards are designed to describe WHY something is required and WHAT needs to be done, many companies fail to create documentation to address HOW the policies and standards are actually implemented. When you "peel back the onion" and want to build an audit-ready cybersecurity and privacy program, there is a need to address "the how" for certain topics, such as vulnerability management, risk management, vendor management and incident response. We did the heavy lifting and created several program-level documents to address this need!
Written Information Security Documentation Starts with Policies & Standards Based on Industry-Recognized Best Practices
A single negligent breach can close your business forever, because your liability insurance may not cover professional negligence if you are unable to provide evidence that you took reasonable steps to prevent a breach or other cybersecurity-related incident. Without the ability to prove steps were taken to ensure due care and due diligence were applied to your business operations, you may be considered negligent in a lawsuit and be fully exposed to fines, penalties and damages.
This is where ComplianceForge can help, since we have the information security solutions that your company needs to be able to prove evidence of due care and due diligence with industry-accepted best practices for IT security. From IT security policies, to risk assessments, to vendor management solutions, we can help you keep your company secure! Documentation serves as the foundational building blocks for your cybersecurity and privacy program. Without properly-scoped policies to address your applicable statutory, regulatory and contractual obligations, your associated standards and procedures will likely be inadequate to meet your compliance needs. The requires a holistic approach to right-sizing your cybersecurity program to meet your organization's specific compliance and security requirements.
Concept of Operations (CONOPS) Provides Program-Level Guidance
A Concept of Operations (CONOPS) is a user-oriented guidance document that describes the mission, operational objectives and overall expectations from an integrated systems point of view, without being overly technical or formal. A CONOPS is meant to:
- Benefit stakeholders by establishing a baseline “operational concept” to establish a conceptual, clearly-understood view for everyone involved in the scope of operations described by the CONOPS.
- Record design constraints, the rationale for those constraints and to indicate the range of acceptable solution strategies to accomplish the mission and any stated objectives.
- Contain a conceptual view that illustrates the top-level functionality in the proposed process or system.
Several ComplianceForge documents are essentially CONOPS documents, where CONOPS are more conceptual than procedures and are focused on providing program-level guidance. A CONOPS straddles the territory between an organization's centrally-managed policies/standards and its decentralized, stakeholder-executed procedures, where CONOPS serves as expert-level guidance that is meant to run a specific function. Examples of where a CONOPS is useful for providing program-level guidance:
- Risk management (e.g., Risk Management Program (RMP))
- Vulnerability management (e.g., Vulnerability & Patch Management Program (VPMP))
- Incident response (e.g., Integrated Incident Response Program (IIRP))
- Business Continuity / Disaster Recovery (e.g., Continuity of Operations Plan (COOP))
- Secure Engineering (e.g., Security & Privacy By Design (SPBD))
- Pre-production testing (e.g., Information Assurance Program (IAP))
- Supply Chain Risk Management (SCRM) (e.g., Cybersecurity Supply Chain Risk Management Program Strategy & Implementation Plan (C-SCRM SIP))
Your organization’s Subject Matter Experts (SMEs) are expected to use a CONOPS as a tool to communicate user needs and system characteristics to developers, integrators, sponsors, funding decision makers and other stakeholders.
Which Product Is Right For You?
Our documentation is meant to address your requirements from strategic concepts all the way down to day-to-day deliverables you need to demonstrate compliance with common statutory, regulatory and contractual obligations.
Give us a call or send us an email - we are happy to help you find the right solution for your needs!
Procedures Operationalize Policies & Standards - This Is A Key Concept To Being Both Secure & Compliant
We leverage the Operationalizing Cybersecurity Planning Model in creating a practical view towards implementing cybersecurity requirements. Organizations are often not at a loss for a set of policies, but executing those requirements often fall short due to several reasons. Standardized Operating Procedures (SOPs) are where the rubber meets the road for Individual Contributors (ICs), since these key players need to know (1) how they fit into day-to-day operations, (2) what their priorities are and (3) what is expected from them in their duties. When looking at it from an auditability perspective, the evidence of due diligence and due care should match what the organization's cybersecurity business plan is attempting to achieve.
The central focus of any procedures should be a Capability Maturity Model (CMM) target that provides quantifiable expectations for People, Processes and Technologies (PPT), since this helps prevent a “moving target” by establishing an attainable expectation for “what right looks like” in terms of PPT. Generally, cybersecurity business plans take a phased, multi-year approach to meet these CMM-based cybersecurity objectives. Those objectives, in conjunction with the business plan, demonstrate evidence of due diligence on behalf of the CISO and his/her leadership team. The objectives prioritize the organization’s service catalog through influencing procedures at the IC-level for how PPT are implemented at the tactical level. SOPs not only direct the workflow of staff personnel, but the output from those procedures provides evidence of due care.
The diagram below helps show the critical nature of documented cybersecurity procedures in keeping an organization both secure and compliant:
Policies, Standards, Function-Specific Guidance & Procedures - How Our Products Support Each Other
The following diagram helps demonstrate the layered nature of cybersecurity documentation. Policies & standards set the stage for teams/departments to create and implement programs that are function-specific.
- A policy on risk will define management's intent to manage risk (RA section of NIST 800-53);
- One of the standards supporting the risk policy might require an annual risk assessment (RA-3);
- Products such as the Risk Management Program (RMP) provide the middle-ground between the policy/standard and the actual deliverable risk assessment to provide risk-specific guidance on concepts such as acceptable risk, the methodology of risk management the organization aligns to, who within the organization can sign off on various levels of risk, etc.
If you would like to know more about how this works, please contact us and we'd be happy to further explain how our documentation links together to create comprehensive, linked cybersecurity and privacy documentation.
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