Asset Focused, Not Auditor Focused
Gunnar Peterson wrote a great piece the other day on the latest productization craze in InfoSec – GRC (Governance, Risk Management and Compliance) wherein he asks "GRC – To Be or To Do?"
I don’t really recall when or from whence GRC sprung up as an allegedly legitimate offering, but to me it seems like a fashionably over-sized rug under which the existing failures of companies to effectively execute on the individual G, R, and C initiatives are conveniently being swept.
I suppose the logic goes something like this: "If you cant effectively
govern, manage risk or measure compliance it must be because what you’re doing is fragmented and siloed. What you need is
a product/framework/methodology that takes potentially digestible
deliverables and perspectives and "evolves" them into a behemoth suite instead?"
I do not dispute that throughout most enterprises, the definitions, approaches and processes in managing each function are largely siloed and fragmented and I see the attractiveness of integrating and standardizing them, but I am unconvinced that re-badging a control and policy framework collection constitutes a radical new approach.
GRC appears to be a way to sell more products and services under a fancy new name to address problems rather than evaluate and potentially change the way in which we solve them. Look at who’s pushing this: large software companies and consultants as well as analysts looking to pin their research to something more meaningful.
From a first blush, GRC isn’t really about governance or managing risk. It’s audit-driven compliance all tarted up.
It’s a more fashionable way of getting all your various framework and control definitions in one place and appealing to an auditor’s desire for centralized "stuff" in order to document the effectiveness of controls and track findings against some benchmark. I’m not really sure where the business-driven focus comes into play?
It’s also sold as a more efficient way of reducing the scope and costs of manual process controls. Fine. Can’t argue with that. I might even say it’s helpful, but at what cost?
GRC (or Governance, Risk Management, and Compliance for
the uninitiated) is all the rage, but I have to say I think that again
Infosec has the wrong focus.
Instead of Risk Management helping to deliver transparent Governance and as a natural by-product demonstrate compliance as a function of the former, the model’s up-ended with compliance driving the inputs and being mislabeled.
As I think about it, I’m not sure GRC would be something a typical InfoSec function would purchase or use unless forced which is part of the problem. I see internal audit driving the adoption which given today’s pressures (especially in public companies) would first start in establishing gaps against regulatory compliance.
If the InfoSec function is considering an approach that drives protecting the things that matter most and managing risk to an acceptable level and one that is not compliance-driven but rather built upon a business and asset-driven approach, rather than make a left turn Gunnar suggested:
Personally, I am happy sticking to classic infosec knitting – delivering confidentiality, integrity, and availability through authentication, authorization, and auditing. But if you are looking for a next generation conceptual horse to bet on, I don’t think GRC is it, I would look at information survivability. Hoff’s information survivability primer is a great starting point for learning about survivability.
Why survivability is more valuable over the long haul than GRC is that survivability is focused on assets not focused on giving an auditor what they need, but giving the business what it needs.
Seminal paper on survivability by Lipson, et al. "survivability solutions are best understood as risk management strategies that first depend on an intimate knowledge of the mission being protected." Make a difference – asset focus, not auditor focus.
For obvious reasons, I am compelled to say "me, too."
I would really like to talk to someone in a large enterprise who is using one of these GRC suites — I don’t really care which department you’re from. I just want to examine my assertions and compare them against my efforts and understanding.