Your organization has invested significant effort in formally documenting its approach toward cybersecurity to enhance accountability and awareness of security processes; however, operationalizing and enforcing this policy library can appear challenging. Failure to consistently enforce cybersecurity policies generally leads to a degradation of the environment, as individuals come to understand that they will not be held accountable for violating corporate decisions and guidelines.
To mitigate this risk and maintain a strong cybersecurity environment, it is crucial to establish clear policy enforcement processes by ensuring that policies are approved by all relevant parties, policies are distributed and communicated, adherence to policies is monitored, and policy exceptions are appropriately managed.
Identify Key Stakeholders and Solicit Feedback
During the development of policies, key stakeholders that will be affected by or responsible for the enforcement of policies should be identified and solicited for feedback. Contention can be reduced by gathering feedback prior to the formal establishment of a policy by ensuring all stakeholders agree with the structure, requirements, and measurement approach.
Key stakeholders are generally thought to include executive management, business unit managers, and operational managers; however, soliciting feedback from non-management personnel educated on best practices or involved in the day-to-day operations, such as security personnel or system users, can be crucial.
Personnel unfamiliar with the policy subject can be beneficial in ensuring the policy is adequately articulated and conveys the intended message. Engaging a variety of individuals not only encourages a culture of shared responsibility and collaboration but also helps uncover potential gaps or ambiguities in the policy that may otherwise go unnoticed.
Policy Distribution, Awareness, and Training
Once the policies have been approved and refined with input from key stakeholders, the next step is to ensure effective distribution. It is essential to maintain consistent storage and version control of all policies by utilizing a centralized document management system readily available to all personnel.
To increase awareness of policy changes, consider leveraging multiple communication channels, such as:
- Email notifications containing policy updates and reminders
- Physical copies of policies located in common areas
- Periodic company-wide meetings or webinars discussing policy changes
Personnel may not always understand the reasoning behind a policy change. To encourage a security-conscious culture, it is essential for the organization to provide awareness and training strategies. For example:
- Explain why the policy is being enforced and describe the risk the policy is designed to mitigate.
- Use real-life examples and scenarios to illustrate the importance of policy adherence.
- Highlight key policy elements and concepts when providing notification of changes, as personnel may not read all policy documents.
- Encourage open dialogue and discussion regarding policy concerns or clarifications.
- Assess employee comprehension through quizzes, simulations, or practical exercises.
Effectively training personnel on the rationale behind policies and encouraging open dialogue to discuss concerns will help foster an environment where security is ingrained in the organization’s culture.
Monitoring Policy Adherence
Consistently monitoring policy adherence is essential to ensure that personnel are following the established company guidelines. Performing regular audits, leveraging automated monitoring tools, and encouraging a culture of reporting can help detect policy violations.
Establishing regular audits is recommended for monitoring policy adherence; in its simplest form, this includes the following steps:
- Determine the audit scope based on the organization’s priorities, risk tolerance, and regulatory requirements.
- The scope should identify and document the policies, processes, controls, and systems that are to be audited. At a minimum, these should include policy updates, policy training and review, incident response testing, periodic access reviews, restoration testing, and vulnerability scans
- Establish an audit calendar and define the frequency of audits. Ensure any regulatory or compliance requirements are identified when establishing audit frequency.
- Communicate the audit plan and objectives with relevant stakeholders, such as department heads and system owners.
- Document audit findings and include evidence of noncompliance or areas for improvement.
- Define and track a plan for remediation efforts.
- This includes establishing timelines for remediation, assigning responsibility to specific personnel, coordinating with relevant stakeholders, and conducting follow-up audits to confirm the effectiveness of remediation efforts.
- Continuously improve the audit process by soliciting feedback from auditors and stakeholders to identify areas of improvement.
When policy violations are detected, addressing them efficiently and consistently is crucial. Management should encourage and reinforce the importance of compliance and provide constructive feedback to personnel to help improve their understanding of the policy. Constructive feedback may involve disciplinary actions, additional training, or process improvements to prevent future occurrences.
Encouraging personnel to feel comfortable reporting potential policy violations or concerns without fear of retribution can help ingrain security into the organization’s culture and foster a secure environment. This can be achieved by maintaining open communication and collaboration or by implementing an anonymous reporting system.
Managing Policy Exceptions
Sometimes policy exceptions may be necessary due to a gap between the current policy and the need to accommodate unique business requirements or unforeseen circumstances. Establishing an exception management process is essential to ensure that exceptions are handled consistently and with appropriate risk management considerations.
At a minimum, an effective policy exception management process includes the following steps:
- Define an exception request process. Often the security team will review exception requests; however, a better approach is to have a management stakeholder or sponsor sign off on the risk and have security advise on the risk and controls.
- Document the business justification, potential risk, and possible compensating controls.
- Communicate exception results with appropriate personnel that may be needed in the implementation of compensating controls or may be affected by the potential risk.
- Define an exception expiration date based on the approval date or a predefined global review period. This ensures that exceptions are periodically reviewed to determine if they are still necessary or if the associated risks have changed.
- Track and consistently review exception requests to identify areas of improvement that may be needed in the currently adopted policy.
Ultimately, the success of an organization’s cybersecurity program depends on the consistent enforcement of security controls and the commitment of all personnel. Effective cybersecurity policy enforcement is critical for maintaining consistency across security controls and is often required to meet obligations with respect to contracts and regulatory requirements.
By soliciting appropriate feedback prior to adopting a policy, distributing and training personnel on the policy, and consistently addressing noncompliance, an organization can foster a culture that continuously improves its security posture and reduces risk.