CISA 27th Edition 3 PDF
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This document provides guidelines for information security governance, focusing on organizational structure, roles, and responsibilities related to IT. It discusses IT governing committees, and the roles played by senior management and boards of directors.
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Guidelines for executing procedures are also the responsibility of operations. Guidelines should contain information that will be helpful in executing the procedures. This can include clarification of policies and standards, dependencies, suggestions and examples, narrative clarifying the procedures...
Guidelines for executing procedures are also the responsibility of operations. Guidelines should contain information that will be helpful in executing the procedures. This can include clarification of policies and standards, dependencies, suggestions and examples, narrative clarifying the procedures, background information that may be useful, and tools that can be used. Guidelines can be useful in many other circumstances as well, but they are considered here in the context of information security governance. 2.4 ORGANIZATIONAL STRUCTURE Organizational structure is a key component to governance. It identifies the key decision-making entities in an enterprise. The following section provides guidance for organizational structures, roles and responsibilities within EGIT. Actual structures may differ depending on the size, industry and location of an enterprise. 2.4.1 IT GOVERNING COMMITTEES Traditionally, organizations have had executive-level steering committees to handle IT issues that are relevant organizationwide. There should be a clear understanding of both the IT strategy and steering levels. ISACA has issued a document offering a clear analysis (figure 2.3). Organizations may also have other executive-and mid-management-led committees guiding IT operations, such as an IT executive committee, IT governance committee, IT investment committee and/or IT management committee. Note: The analysis of IT steering committee responsibilities is information the CISA should know. 2.4.2 ROLES AND RESPONSIBILITIES OF SENIOR MANAGEMENT AND BOARDS OF DIRECTORS Information security governance requires strategic direction and impetus. It requires commitment, resources and assignment of responsibility for information security management as well as a means for the board to determine that its intent has been met. Effective information security governance can be accomplished only by involvement of the board of directors and/or senior management in approving policy; ensuring appropriate monitoring; and reviewing metrics, reports and trend analysis. Board of Directors Members of the board need to be aware of the organization’s information assets and their criticality to ongoing business operations. This can be accomplished by periodically providing the board with the high-level results of comprehensive risk assessments and business impact analysis (BIA). It may also be accomplished by business dependency assessments of information resources. These activities should include approval by board members of the assessment of key assets to be protected, which helps ensure that protection levels and priorities are appropriate to a standard of due care. The tone at the top must be conducive to effective security governance. It is unreasonable to expect lower-level personnel to abide by security measures if they are not exercised by senior management. Senior management endorsement of intrinsic security requirements provides the basis for ensuring that security expectations are met at all levels of the enterprise. Penalties for noncompliance must be defined, communicated and enforced from the board level down. Figure 2.3—Analysis of IT Steering Committee Responsibilities Level IT Strategy Committee IT Steering Committee Responsibility Provides insight and advice to the Decides the overall level of IT board on topics such as: spending and how costs will be – The relevance of developments in allocated IT from a business perspective Aligns and approves the enterprise’s – The alignment of IT with the IT architecture business direction Approves project plans and budgets, – The achievement of strategic IT setting priorities and milestones objectives Acquires and assigns appropriate – The availability of suitable IT resources resources, skills and Ensures that projects continuously infrastructure to meet the meet business requirements, strategic objectives including reevaluation of the – Optimization of IT costs, business case including the role and value Monitors project plans for delivery delivery of external IT sourcing of expected value and desired – Risk, return and competitive outcomes, on time and within aspects of IT investments budget – Progress on major IT projects Monitors resource and priority – The contribution of IT to the conflict between enterprise divisions business (i.e., delivering the and the IT function as well as promised business value) between projects – Exposure to IT risk, including Makes recommendations and compliance risk requests for changes to strategic – Containment of IT risk plans (priorities, funding, – Direction to management relative technology approaches, resources, to IT strategy etc.) – Drivers and catalysts for the Communicates strategic goals to board’s IT strategy project teams Is a major contributor to management’s IT governance responsibilities and practices Authority Advises the board and management Assists the executive in the delivery on IT strategy of the IT strategy Is delegated by the board to provide Oversees day-to-day management of input to the strategy and prepare its IT service delivery and IT projects approval Focuses on implementation Focuses on current and future strategic IT issues Membership Board members and specialists who Sponsoring executive are not board members Business executives (key users) Chief information officer (CIO) Key advisors as required (i.e., IT, audit, legal, finance) The board of directors is the accountable and liable body for the organization. Accountability means the board takes the responsibility of ensuring the organization follows the laws, behaves in an ethical manner, and makes effective use of its resources. Senior Management Implementing effective security governance and defining the strategic security objectives of an organization is a complex task. As with any other major initiative, it must have leadership and ongoing support from executive management to succeed. Developing an effective information security strategy requires integration with and cooperation of business process owners. A successful outcome is the alignment of information security activities in support of business objectives. The extent to which this is achieved will determine the cost-effectiveness of the information security program in achieving the desired objective of providing a predictable, defined level of assurance for business information and processes and an acceptable level of impact from adverse events. Information Security Standards Committee Security affects all aspects of an organization to some extent, and it must be pervasive throughout the enterprise to be effective. To ensure that all stakeholders impacted by security considerations are involved, many organizations use a steering committee comprised of senior representatives of affected groups. This facilitates achieving consensus on priorities and trade- offs. It also serves as an effective communications channel and provides an ongoing basis for ensuring the alignment of the security program with business objectives. It can also be instrumental in achieving modification of behavior toward a culture more conducive to good security. The chief information security officer (CISO) will primarily drive the information security program to have realistic policies, standards, procedures and processes that are implementable and auditable and to achieve a balance of performance in relation to security. However, it is necessary to involve the affected groups in a deliberating committee, which may be called the information security standards committee (ISSC). The ISSC includes members from C-level executive management and senior managers from IT, application owners, business process owners, operations, HR, audit and legal. The committee will deliberate on the suitability of recommended controls and good practices in the context of the organization, including the secure configuration of operating systems (OSs) and databases. The auditor’s presence is required to make the systems auditable by providing for suitable audit trails and logs. Legal is required to advise on liability and conflicts with the law. This is not a prescriptive list of members to be included on the ISSC. Members of the committee may be modified to suit the context of the organizations, and other members may be co-opted as necessary to suit the control objectives in question. Chief Information Security Officer All organizations have a CISO whether or not anyone holds the exact title. The responsibilities may be performed by the CIO, CTO, CFO or, in some cases, the CEO, even when there is an information security office or director in place. The scope and breadth of information security is such that the authority required and the responsibility taken will inevitably make it a senior officer or top management responsibility. This could include a position such as a CRO or a CCO. Legal responsibility will, by default, extend up the command structure and ultimately reside with senior management and the board of directors. Failure to recognize this and implement appropriate governance structures can result in senior management being unaware of this responsibility and the related liability. It also usually results in a lack of effective alignment of business objectives and security activities. Increasingly, prudent management is elevating the position of information security officer to a senior management position, as organizations increasingly recognize their dependence on information and the growing threats to it. IT Steering Committee The enterprise’s senior management should appoint a planning or steering committee to oversee the IT function and its activities. A high-level steering committee for information systems is an important factor in ensuring that the IT department is in harmony with the corporate mission and objectives. Although not a common practice, it is highly desirable that a member of the board of directors who understands the risk and issues is responsible for IT and is chair of this committee. The committee should include representatives from senior management, each line of business, corporate departments, such as HR and finance, and the IT department. The committee’s duties and responsibilities should be defined in a formal charter. Members of the committee should know IT department policies, procedures and practices. They should have the authority to make decisions within the group for their respective areas. This committee typically serves as a general review board for major IS projects and should not become involved in routine operations. Primary functions performed by this committee include: Reviewing the long- and short-range plans of the IT department to ensure that they align with the corporate objectives. Reviewing and approving major acquisitions of hardware and software within the limits approved by the board of directors. Approving and monitoring major projects and the status of IS plans and budgets, establishing priorities, approving standards and procedures, and monitoring overall IS performance. Reviewing and approving sourcing strategies for select or all IS activities, including insourcing or outsourcing, and the globalization or offshoring of functions. Reviewing adequacy of resources and allocation of resources in terms of time, personnel and equipment. Making decisions regarding centralization versus decentralization and assignment of responsibility. Supporting development and implementation of an enterprisewide information security management program. Reporting to the board of directors on IS activities. Note: Responsibilities will vary from enterprise to enterprise; the responsibilities listed are the most common responsibilities of the IT steering committee. Each enterprise should have formally documented and approved terms of reference for its steering committee, and IS auditors should familiarize themselves with the IT steering committee documentation and understand the major responsibilities that are assigned to its members. Many enterprises may refer to this committee with a different name. The IS auditor needs to identify the group that performs the previously mentioned functions. Matrix of Outcomes and Responsibilities The relationships between the outcomes of effective security governance and management responsibilities are shown in figure 2.4. This matrix is not meant to be comprehensive but is intended merely to indicate some primary tasks and the management level responsible for those tasks. Depending on the nature of the organization, the titles may vary, but the roles and responsibilities should exist even if different labels are used. Note: While figure 2.4 is not specifically tested in the CISA exam, the CISA candidate should be aware of this information. Source: ISACA, Information Security Governance: Guidance for Information Security Managers, 2008 2.4.3 IT ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES An IT department can be structured in different ways. One such format is shown in figure 2.5. The organizational chart depicted includes functions related to security, applications development and maintenance, technical support for network and systems administration, and operations. The organizational structure shows the IT department typically headed by an IT manager/director or, in large organizations, by a CIO. Note: The CISA exam does not test specific job responsibilities because they may vary among organizations. However, universally known responsibilities such as business owners, information security functions and executive management might be tested, especially when access controls and data ownership are tested. A CISA should be familiar with SoD. IT Roles and Responsibilities An organizational chart is an important item for all employees to know, because it provides a clear definition of the department’s hierarchy and authorities. Additionally, job descriptions; responsible, accountable, consulted, informed (RACI) charts; and swimlane workflow diagrams provide IT department employees a more complete and clear direction regarding their (and others’) roles and responsibilities. The IS auditor should spend time in an auditee’s area to observe and determine whether the formal job description and structures coincide with real ones and are adequate. Generally, the following IT functions should be reviewed: Systems development manager—Systems development managers are responsible for programmers and analysts who implement new systems and maintain existing systems. Project management—Project managers are responsible for planning and executing IS projects and may report to a project management office or to the development organization. Project management staff use budgets assigned to them for the delivery of IS initiatives and report on project progress to the IT steering committee. Project managers play a central role in executing the vision of the IT strategy and IT steering committees by planning, coordinating and delivering IT projects to the enterprise. Help desk (service desk)—More and more companies find a help desk function critical for their IT departments. A help desk is a unit within an organization that responds to technical questions and problems faced by users. Most software companies have help desks. Questions and answers can be delivered by telephone, fax, email or instant messaging. Help desk personnel may use third-party help desk software that enables them to quickly find answers to common questions. A procedure to record the problems reported, solved and escalated should be in place for analysis of the problems/questions. It helps in monitoring the user groups and improving the software/information processing facility (IPF) services. – Help desk/support administration includes the following activities: Acquire hardware/software (HW/SW) on behalf of end users. Assist end users with HW/SW difficulties. Train end users to use HW/SW and databases; answer end-user queries. Monitor technical developments and inform end users of pertinent developments. Determine the source of problems with production systems and initiate corrective actions. Inform end users of problems with HW/SW or databases that could affect their control of the installation of HW/SW upgrades. Initiate changes to improve efficiency. End user—End users are responsible for operations related to business application services. There is a small distinction between the terms “end user” and “user.” End user is slightly more specific and refers to someone who will access a business application. User is broader and could refer to administrative accounts and accounts to access platforms. End-user support manager—The end-user support manager acts as a liaison between the IT department and the end users. Data management—Data management personnel are responsible for the data architecture in larger IT environments and tasked with managing data as corporate assets. Quality assurance (QA) manager—The QA manager is responsible for negotiating and facilitating quality activities in all areas of IT. Information security management—This is a function that generally needs to be separate from the IT department and headed by a CISO. The CISO may report to the CIO or have a dotted-line (indirect reporting) relationship to the CIO. Even when the security officer reports to the CIO, there is a possibility of conflict because the goals of the CIO are to efficiently provide continuous IT services whereas the CISO may be less interested in cost reduction if this impacts the quality of protection. Vendor and Outsourcer Management With the increase in outsourcing, including the use of multiple vendors, dedicated staff may be required to manage the vendors and outsourcers. This may necessitate staff performing the following functions: Acting as the prime contact for the vendor and outsourcer within the IT function Providing direction to the outsourcer on issues and escalating internally within the organization and IT function Monitoring and reporting on the service levels to management Reviewing changes to the contract due to new requirements and obtaining IT approvals Infrastructure Operations and Maintenance An operations manager is responsible for computer operations personnel, including all the staff required to run the data center efficiently and effectively (e.g., computer operators, librarians, schedulers and data control personnel). The data center includes the servers and mainframe, peripherals such as high-speed printers, networking equipment, magnetic media, and storage area networks. It constitutes a major asset investment and impacts the organization’s ability to function effectively. The control group is responsible for the collection, conversion and control of input, and the balancing and distribution of output to the user community. The supervisor of the control group usually reports to the IPF operations manager. The input/output control group should be in a separate area where only authorized personnel are permitted since they handle sensitive data. Media Management Media management is required to record, issue, receive and safeguard all program and data files that are maintained on removable media. Depending on the size of the organization, this function may be assigned to a full-time individual or a member of operations who also performs other duties. This is a crucial function. Therefore, many organizations provide additional support through the use of software that assists in maintaining inventory, movement, version control and configuration management. Data Entry Data entry is critical to the information processing activity and includes batch entry or online entry. In most organizations personnel in user departments do their own data entry online. In many online environments, data are captured from the original source (e.g., electronic data interchange [EDI] input documents, data captured from bar codes for time management, departmental store inventory). The user department and the system application must have controls in place to ensure that data are validated, accurate, complete and authorized. Supervisory Control and Data Acquisition With the advancement of technology and need to acquire data at their origination site, automated systems for data acquisition are being deployed by organizations. These systems include barcode readers or systems that are referred to as supervisory control and data acquisition (SCADA). The term SCADA usually refers to centralized systems that monitor and control entire sites, or complexes of systems spread out over large areas (on the scale of kilometers or miles). These systems are typical of industrial plants, steel mills, power plants, electrical facilities and similar. Most site control is performed automatically by remote terminal units (RTUs) or by programmable logic controllers (PLCs). Host control functions are usually restricted to basic site overriding or supervisory level intervention. An example of automated systems for data acquisition are those used on oil rigs to measure and control the extraction of oil and to control the temperature and flow of water. Data acquisition begins at the RTU or PLC level and includes meter readings and equipment status reports that are communicated to SCADA as required. Data are then compiled and formatted in such a way that a control room operator using human machine interfacing (HMI) networks can make supervisory decisions to adjust or override normal RTU or PLC controls. Data may also be fed to a history log, often built on a commodity database management system, to allow trending and other analytical auditing. SCADA applications traditionally used dedicated communication lines, but there has been a significant migration to the Internet. This has obvious advantages, among them easier integration in the company business applications. However, a disadvantage is that many such companies are nation-critical infrastructures and become easy prey to cyberattacks. Systems Administration The systems administrator is responsible for maintaining major multiuser computer systems, including local area networks (LANs), wireless local area networks (WLANs), wide area networks (WANs), virtual machine/server/network environments, personal area networks (PANs), storage area networks (SANs), intranets and extranets, and mid-range and mainframe systems. Typical duties include the following activities: Adding and configuring new workstations and peripherals Setting up user accounts Installing systemwide software Performing procedures to prevent/detect/correct the spread of viruses Allocating mass storage space Small organizations may have one systems administrator, whereas larger enterprises may have a team of them. Some mainframe-centric organizations may refer to a systems administrator as a systems programmer. Security Administration Security administration begins with management’s commitment. Management must understand and evaluate security risk and develop and enforce a written policy that clearly states the standards and procedures to be followed. The duties of the security administrator should be defined in the policy. To provide adequate SoD, this individual should be a full-time employee who may report directly to the infrastructure director. However, in a small organization, it may not be practical to hire a full-time individual for this position. The individual performing the function should ensure that the various users are complying with the corporate security policy and controls are adequate to prevent unauthorized access to the company assets (including data, programs and equipment). The security administrator’s functions usually include: Maintaining access rules to data and other IT resources. Maintaining security and confidentiality over the issuance and maintenance of authorized user IDs and passwords. Monitoring security violations and taking corrective action to ensure that adequate security is provided. Periodically reviewing and evaluating the security policy and suggesting necessary changes to management. Preparing and monitoring the security awareness program for all employees. Testing the security architecture to evaluate the security strengths and detect possible threats. Working with compliance, risk management and audit functions to ensure that security is appropriately designed and updated based on audit feedback or testing. Database Administration The database administrator (DBA), as custodian of an organization’s data, defines and maintains the data structures in the corporate database system. The DBA must understand the organization and user data and data relationship (structure) requirements. This position is responsible for the security of the shared data stored on database systems. The DBA is responsible for the actual design, definition and proper maintenance of the corporate databases. The DBA usually reports directly to the director of the IPF. The DBA’s role includes: Specifying the physical (computer-oriented) data definition. Changing the physical data definition to improve performance. Selecting and implementing database optimization tools. Testing and evaluating programming and optimization tools. Answering programmer queries and educating programmers in the database structures. Implementing database definition controls, access controls, update controls and concurrency controls. Monitoring database usage, collecting performance statistics and tuning the database. Defining and initiating backup and recovery procedures. The DBA has the tools to establish controls over the database and the ability to override these controls. The DBA also has the capability of gaining access to all data, including production data. It is usually not practical to prohibit or completely prevent access to production data by the DBA. Therefore, the IT department must exercise close control over database administration through the following approaches: SoD Management approval of DBA activities Supervisor review of access logs and activities Detective controls over the use of database tools Systems Analyst Systems analysts are specialists who design systems based on the needs of the user and are usually involved during the initial phase of the system development life cycle (SDLC). These individuals interpret the needs of the user and develop requirements and functional specifications as well as high- level design documents. These documents enable programmers to create a specific application. Security Architect Security architects evaluate security technologies; design security aspects of the network topology, access control, identity management and other security systems; and establish security policies and security requirements. One may argue that systems analysts perform the same role; however, the set of skills required is quite different. The deliverables (e.g., program specifications versus policies, requirements, architecture diagrams) are different as well. Security architects should also work with compliance, risk management and audit functions to incorporate their requirements and recommendations for security into the security policies and architecture. System Security Engineer The system security engineer, as defined under ISO/IEC 21827:2008: Information technology—Security techniques—Systems Security Engineering —Capability Maturity Model, provides technical information system security engineering support to the organization that encompasses the following: Project life cycles, including development, operation, maintenance and decommissioning activities Entire organizations, including management, organizational and engineering activities Concurrent interactions with other disciplines, such as system software and hardware, human factors, test engineering, system management, operation and maintenance Interactions with other organizations, including acquisition, system management, certification, accreditation and evaluation Applications Development and Maintenance Applications staff are responsible for developing and maintaining applications. Development can include developing new code or changing the existing setup or configuration of the application. Staff develop the programs or change the application setup that will ultimately run in a production environment. Therefore, management must ensure that staff cannot modify production programs or application data. Staff should work in a test-only environment and turn their work to another group to move programs and application changes into the production environment. Infrastructure Development and Maintenance Infrastructure staff are responsible for maintaining the systems software, including the OS. This function may require staff to have broad access to the entire system. IT management must closely monitor activities by requiring that electronic logs capture this activity and are not susceptible to alteration. Infrastructure staff should have access to only the system libraries of the specific software they maintain. Usage of domain administration and superuser accounts should be tightly controlled and monitored. Network Management Today many organizations have widely dispersed IPFs. They may have a central IPF, but they also make extensive use of: LANs at branches and remote locations WANs, where LANs may be interconnected for ease of access by authorized personnel from other locations Wireless networks established through mobile devices Network administrators are responsible for key components of this infrastructure (e.g., routers, switches, firewalls, network segmentation, performance management, remote access). Because of geographical dispersion, each LAN may need an administrator. Depending on the policy of the company, these administrators can report to the director of the IPF or, in a decentralized operation, may report to the end-user manager, although at least a dotted line to the director of the IPF is advisable. This position is responsible for technical and administrative control over the LAN. This includes ensuring that transmission links are functioning correctly, backups of the system are occurring, and software/hardware purchases are authorized and installed properly. In smaller installations this person may be responsible for security administration over the LAN. The LAN administrator should have no application programming responsibilities but may have systems programming and end-user responsibilities. 2.4.4 SEGREGATION OF DUTIES WITHIN IT Actual job titles and organizational structures vary greatly from one organization to another depending on the size and nature of the business. However, an IS auditor should obtain enough information to understand and document the relationships among the various job functions, responsibilities and authorities, and assess the adequacy of the SoD. SoD avoids the possibility that a single person could be responsible for diverse and critical functions in such a way that errors or misappropriations could occur and not be detected in a timely manner and in the normal course of business processes. SoD is an important means by which fraudulent and/or malicious acts can be discouraged and prevented. Duties that should be segregated include: Custody of the assets Authorization Recording transactions If adequate SoD does not exist, the following could occur: Misappropriation of assets Misstated financial statements Inaccurate financial documentation (i.e., errors or irregularities)