[BreachExchange] 7 Steps to Start Your Risk Assessment

Destry Winant destry at riskbasedsecurity.com
Mon Oct 29 03:58:18 EDT 2018


"Managing risk is one of the most, if not the most important,
functions in an organization," says Tony Martin-Vegue, enterprise
security management strategist for LendingClub, a peer-to-peer lending
company based in San Francisco. "It's really important to have a
structured, formalized process for measuring risk, managing risk, and
the entire remediation process."

If a formal process is the best way to assess and manage risk, then
what sort of process should an organization use? "The most commonly
used risk model is the mental model of the person waving their wet
finger in the air," says Jack Jones, executive vice president of
research and development at RiskLens and chairman of the FAIR
Institute. "And mental models are notoriously flawed," he says. The
reliance on flawed mental models is one of the many reasons Jones says
that the IT industry is horrible at properly assessing risk.

How does an organization go about finding a better model and using it
to figure out what their risk is? There are a number of options, from
NIST SP 800-30 to aspreadsheet-based model that can be found from a
wide variety of sources with a quick Google search to FAIR — Factor
Analysis of Information Risk.

Large organizations will have teams dedicated to assessing and
re-assessing risk on a regular basis. Small organizations may lack the
team, but they will not lack the need to understand what risks IT
faces and how those risks are reflected in the rest of the business

"I don't feel any organization can even begin to think about what it
wants to do from an information security perspective without making
some proper attempt at being able to understand the risks that matter
most to their organization," says Zulfikar Ramzan, CTO of RSA. "I
don't want this to be confused with 'expensive' or 'complex' or, you
know, beyond the scope of what I think even a small- to medium-sized
organization can do," he explains. "What I really mean here is try to
be a bit principled trying to look at it and get a more quantitative

Getting started on this quantitative path can be confusing, so Dark
Reading researched the major frameworks and spoke with Jones,
Martin-Vegue, and Ramzan to get their ideas on best initial steps. We
found seven steps that apply to a variety of frameworks — and that are
applicable no matter where the process takes your organization.

Start With a Common Language

"I think [risk assessment] does start with at least beginning with a
consistent definition of what risk means," says Ramzan. Agreeing on
language is important because there are so many terms that will be
used by everyone involved in the process and so many decisions that
need to be made on the outcome of the process.

Among the most important terms to be agreed on are assets, value,
losses, threats, and measurements. And the reason that there should be
formal, stated agreement on the language is that many of the terms
have meanings that can vary from discipline to discipline, or even
person to person based on their background and experience.

Once there's agreement on the terms to be used and their meanings,
it's time to start assigning values to those terms.

Define Assets

An asset is anything that brings potential value — or represents
potential risk — to the organization. The critical point to be made in
figuring out whether something is an asset, is that the value or risk
doesn't have to be represented solely in dollar amounts.

Assets can be materials and equipment, or they can be customer data,
intellectual property, or the organization's reputation. While the
categories into which assets can fit is large, it's important to know
that, from a risk analysis perspective, not everything is an asset.

Why would it matter if there are extra "assets" on the list? Jones
describes a problem he frequently sees. "You have a severe
signal-to-noise ratio problem," he says. "The risk registers are
filled with things that are part of risk landscape but aren't
themselves risks." Deciding whether something belongs on this list is
going to depend on whether value and risk of loss can be defined — and
those come next.

Define Value

In the FAIR model there are three kinds of value (and their mirror
image, loss). The first of these is criticality — the impact the asset
has on the organization's productivity. Is something a component in
manufacturing? Is it part of the billing process? Is it key to selling
the organization's products or services? If so, then its criticality
value will be high.

The next value is competitive advantage. Does the asset allow the
organization to do something its competitors can't do, or do something
in a way that's superior to the way the competition does it? Then it
has value from a competitive advantage standpoint.

The final value/risk is sensitivity, basically a measure of how much
the asset's loss will cost the organization. The model breaks this
value into four separate risks:

- Embarrassment -– Would having this information become public show
that the organization had engaged in unethical or unsavory activities?

- Competitive advantage –- How significant an impact does this have on
the overall competitive advantage of the organization?

- Legal/regulatory -– Is this asset regulated by national or industry
agencies? Would disclosure or loss of this asset prove a violation of
regulations or law?

- General -– And this is the catch-all for assets that don't neatly
fit into one of the other categories, but are still important to the
organization, and a risk if they're lost, exposed, or compromised.

Define Losses

Just as there are multiple ways of determining value, there are many
ways of looking at the loss of an asset. The FAIR method describes six
categories of loss in their model:

- Productivity –- A loss doesn't have to bring the effective
production of goods or services to a halt; all it has to do is reduce
the effectiveness. If that happens, a loss has occurred.
- Response -– Most organizations won't ignore a loss that occurs
regarding one of their assets; they will respond. The cost of that
response, whether large or small, is a loss that must be considered.
- Replacement -– Speaking of responses, if an asset is lost or damaged
it will be replaced. The cost of that replacement is a loss to the
- Fines and judgments -– If the loss exposes the organization to legal
or regulatory action, the cost of responding in court and of any fines
or judgments is part of the overall loss.
- Competitive advantage -- When a loss alters the competitive
landscape or forces the organization to miss sales opportunities
because of the incident or response, then it's a loss to competitive
- Reputation -– And if the incident makes potential customers,
clients, or partners think less of the organization and its business
suffers for that, then it's a material loss to reputation that must be
taken into account.

Define Threats

Threats can come in many forms and guises, from outside the
organization and inside, from malicious acts to accidents, and from
human action to force majeure.

Regardless of the threat's source, it will have an impact in one of
five ways on an asset:

- Access -– The threat can read or gain access to the data without
proper authorization.
- Deny access -– The threat agent can prevent legitimate users from
accessing the asset.
- Disclose -– The threat can let other people or organizations access the asset.
- Misuse -– The threat can use the asset in ways that were never
intended or authorized.
- Modify -– The threat can change the asset, whether data or configuration.

Define Measurements

How will you define the impact of a loss? It's easy to say that
dollars are all that matter, but individual stake-holders may define
the impact differently. "If you think about the concept of a risk
owner, that is somebody who owns the risk, somebody who essentially
has their neck on the line," says Martin-Vegue. "If something goes
south, this is the person that's accountable."

Measurement is important because so many of the decisions to be made
around risk assessment involve multiple business units and management
teams. Martin-Vegue explains, "Let's say you can implement this new
product that has a ton of vulnerabilities but it also gets me all of
this new revenue - it increases my business. So what should I do?" he
asks, continuing, "Should I put the new product in and take the risk
with cyber vulnerabilities, or should I not put the product in and
take the risk of not getting new customers?

Martin-Vegue points out that these are the sorts of decisions that
involve multiple stakeholders from multiple business units. Without
common definitions of terms, threats, and measurements, making those
decisions in a rational way is all but impossible.

Define the Audience

Why, precisely, is the organization going through the process of risk
assessment? Knowing the reasons for the exercise, and therefore the
audience for the final assessment, will help guide the language
decisions in the report that results. "Risk assessments and risk
management always always needs to support a management decision," says
Martin-Vegue, adding, "Before you embark on any risk analysis you
really need to ask yourself, 'what decisions am I supporting?'"

In almost all organizations, those decisions will come down to
answering questions about how to spend resources. "When you look at
risk and it being multifaceted as it is, it's very easy to overspend
in certain areas and underspend and others," says Ramzan. "We have to
make sure we think about risk with a holistic and balanced view that
enables us to spend money in the correct ways."

Spending in correct ways is ultimately a decision for the executive
committee, and a rigorous risk assessment leading to a report written
in business language will support that decision. Jones says, "How I
think about it is this: our problem space is complex and dynamic with
a lot at stake, and we have limited resources. Every dollar that goes
to us is a dollar that doesn't go to growing the business or other
operation imperatives, so it's critically important that we

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