Risk Management What Works The Main Event 2nd Annual GRC Symposium May 16, 2012 Brookfield, Wisconsin. Mark T. Chapman, CISSP, CISM, CRISC Chapman Technology Group, Inc. www.PhishLine.com mchapman @ phishline.com Copyright © 2012, Chapman Technology Group, Inc. All Rights Reserved. In theory, Risk Management should be easy. Identify critical assets, consider potential risks, evaluate mitigating factors, measure results, take action, and repeat. In practice, many organizations struggle with the basic terms and concepts. For those who master the concepts, the “exponentially increasing complexity” of risk management efforts can quickly overwhelm organizations of every size. Risk Assessment for a Television Interview I primarily didn’t want to: • Look like an idiot. • Get sued for saying or doing anything dumb. Secondarily, I didn’t want to • Be rushed to get there or be late. Preemptive Mitigation for a Television Interview • • • • • • Extra suit in the car. Extra laptop. Charge cellphone and laptops. Practice the demo. Gas up the car the night before. Leave the house early. Unanticipated Risks for a Television Interview • Required Cell phone was completely discharged 2 hours before the shooting. • I almost tripped on a lighting cable in the studio. Damage Assessment for a Television Interview Financial Loss: While shooting the in-thefield portion of the story, I got a parking ticket ! Threat Source Risk Area Strategic Harm Reputation Damage Technical Breaches Compliance Failure Confidentiality Integrity Availability Liability Policy Financial Loss Category Threat Source Risk Area Strategic Harm Reputation Damage Technical Breaches Compliance Failures Confidentiality Integrity Availability Liability Policy Financial Loss Category Threat Source Category Risk Area Threat Source Category Risk Area Reputation Damage Threat Source Category Risk Area Reputation Damage Threat Source Category Reputation Damage Liability Risk Area Threat Source Category Reputation Damage Liability Risk Area Threat Source Category Reputation Damage (Reputation Damage, Employees 5) Liability Risk Area Threat Source Category Reputation Damage (Reputation Damage, Employees 5) Liability Risk Area (Reputation Damage, Liability 3) (Employees, Liability 1) Threat Source Category Reputation Damage (Reputation Damage, Employees 5) Liability Risk Area (Reputation Damage, Liability 3) (Employees, Liability 1) Threat Source Category Reputation Damage (Reputation Damage, Employees 5) Liability Risk Area (Reputation Damage, Liability 3) (Employees, Liability 1) Threat Source Liability Category Risk Area Reputation Damage (Reputation Damage, Liability 3) This “Cublet” is a specific Risk Area, Threat Source, and Category. The score is computed by the Projected values. (Reputation Damage, Employees 5) Score(Reputation Damage, Employees, Liability) = Function(1, 3, 5) Did the “formal process” help? • Preemptive Mitigation? • Unanticipated Risks? • Damage Assessment? • Why or Why Not? What Works! • • • • People manage risk ALL THE TIME. Companies manage risks ALL THE TIME. It should feel natural, logical, And, Risk Management should ALWAYS pass the “Common Sense” test. High-Level Approach – PUSH • • • • Preparation Universe Definition Scoring Hitting the Mark PUSH Approach was first presented to the FFIEC Information Technology Conference by Mark Chapman in 2007. Preparation • • • • • Earn Management Buy-In Decide to In-Source or Outsource Anticipate the Benefits Identify the Specific Purpose Evaluate Automation Options Earn Management Buy-In Motivators: • Compliance / Fear • Means to justify other initiatives • New Management Eager to Learn • “True Believers” Results: 1. Go through the motions 2. Do it right Challenges: • “It costs money” • “I already know the risks better than anyone” • “We have more important things to do” In-Source or Outsource? • Current Capability – Do we have the capability or can we train in-house? – Can we identify a firm with independent, knowledgeable and sufficient resources? • Future Capability – Turnover of trained employees – Dependence on consultants Anticipated Benefits • • • • • To learn something new To validate or quantify a concern To standardize communication of risk To establish common language and tools To satisfy the auditors Specific Purpose • • • • • • • • Audit Planning Budgeting Compliance Disaster Recovery Policy Writing Risk Management Remediation Vendor Selection Hint: You must understand the specific purpose of the risk management project Automation • Paper • Excel / Word • Specialized Software High-Level Approach - PUSH™ • • • • Preparation Universe Definition Scoring Hitting the Mark Universe Definition • Goal: – To Define an Appropriate Universe for the Size and Complexity of the Institution • Choose the Number of “Dimensions” – Assets, Risks, Controls • For Each Dimension – Define Scope, Granularity, Level of Detail – Populate the Universe Risk Assessment Math It seems Easy! • Assets – “Valuables” which must be protected • Risks – “Bad things” that could happen to “Valuables” • Controls – “Mitigating Factors” to limit impact of “Bad Things” Why is it so Difficult to Implement? • 50 Assets X 50 Risks X 50 Controls = 125,000 Combinations! • 600 Assets X 70 Risks = 42,000 Combinations before we get to controls! Copyright © 2005-2008, Chapman Technology Group, Inc. All Rights Reserved. Risk Management Universe Assets Controls 3-Dimensions* •Assets •Risks •Controls * Technically, there is a fourth dimension, Instead of “Time” it is “Testing” which gets into Risk Monitoring. Copyright © 2005-2008, Chapman Technology Group, Inc. All Rights Reserved. 2-Dimensional Example How Many Dimensions? Scope Business Impact Analysis Inherent Risk Assessment Risk-Based Audit Plan Disaster Recovery Plan Risk-Based Audit Assets Risks Controls Asset Universe Scope Business Functions Fixed-Assets Strategies Brands Contracts Cash Intellectual Property Products People Granularity Detail How many levels of assets do we want to consider? How much information do we want to understand for each asset? Buildings Rooms Individual Bricks Asset Type Asset Owner Importance Dependencies Assets - Level of Detail Determine the attributes to characterize assets. Hint: Keep the list small and add as needed. Assets – Documentation* Take the opportunity to centralize asset documentation: • Pictures, Diagrams, Schematics, Building Plans • Policies, Procedures • Contracts, Licenses, Vendor Data • Phone #’s, Key Contacts, Password Escrow *Do the same thing for Risks and Controls Example #1: Keep pictures of fire suppression, power and other critical infrastructure Example #2: Attach pictures of bad check writers Risk Universe Scope Power Outage Pandemics Water Damage Fraud Computer Hacking Employee Turnover Tampering Granularity Detail How many levels of risks do we want to consider? How much information do we want to understand for each risk? City-Wide Blackout Accidental Power Disconnect Mouse Chews Through Power Cord Risk Type Threat Source Likelihood Impact Risks - Level of Detail Determine the attributes to characterize risks. Hint: Keep the list small and add as needed. Controls Universe Scope Financial Physical Technological Reputation Legal Insurance Granularity Detail How many levels of controls do we want to consider? How much information do we want to understand for each control? Use a Framework Individual “Bricks” Control Owner Effectiveness Compliance Info Assessment Criteria Controls - Level of Detail Determine the attributes to characterize controls. Hint: Keep the list small and add as needed. High-Level Approach - PUSH™ • • • • Preparation Universe Definition Scoring Hitting the Mark Scoring • • • • • Choose Scale Normalize Prioritize and Trim Associate Adjust Compound Scores Choose Scale Define a consistent scale. • • Numeric (1-5), (0.0-1.0), (1-3), (0%-100%) Descriptive (Low, Med, High), (Nice-To-Have, Normal, Critical) Normalize Set the Relative Importance of: • Risks with respect to other Risks • Assets to other Assets • Controls to other Controls Prioritize and Trim Goal: To combat the natural exponential growth of assessment efforts by reducing the number of lowpriority assets, risks and controls. Approach: Select a threshold for exclusion from further risk assessment efforts while documenting decision. Retain all excluded data to accommodate priority changes and to reduce duplicate analysis next time. Associate 1. Be Selective 2. Use Common Sense 3. Document Reasons for Exceptions Adjust Compound Scores Use Initial Scores with Few Documented Exceptions. High-Level Approach - PUSH™ • • • • Preparation Universe Definition Scoring Hitting the Mark Hitting the Mark • • • • Evaluate Intended Specific Purpose Write the “Final Report” Track Actions Over Time Evaluate Project Effectiveness Intended Specific Purpose The Risk Management can only “Hit the Mark” if it serves a purpose: – – – – – – – – Audit Planning Budgeting Compliance Disaster Planning Policy Writing Risk Management Remediation Vendor Selection Inventory Assets Characterize Assets Advance Important Items Identify Raw Risks Consider Mitigating Factors Calculate Residual Risk Exposure Advance Areas of Higher Risk Create Audit Plan Create Audit Program Write the “Final Report” • Do not – Put too much emphasis on the final deliverable – Think “bigger is better” • Do focus on – – – – Process used (brief) Discoveries Trends Actions (proposed, planned or completed) Manage Observations/Findings Copyright © 2005-2007, Chapman Technology Group, Inc. All Rights Reserved. Manage Observations/Findings Copyright © 2005-2007, Chapman Technology Group, Inc. All Rights Reserved. Evaluate Effectiveness • What did you learn through the process? • What unexpected benefits did you realize? • How did you keep the process from getting too detailed or out of control? • How can you improve the process next time? • These charts look scientific and absolute how did you handle the inherent subjectivity? • Did you achieve your objectives? Additional Consideration • • • • • • • Risk Tolerance Trending Monitoring Disaster Recovery Planning Monte Carlo Simulations Surveys Testing Conclusion - PUSH™ • • • • Preparation Universe Definition Scoring Hitting the Mark What Works! 1. Identify what you want to protect (Assets). What bad things could happen (Risks). Mitigating Factors (Controls). 2. Look at what has changed since last assessment. (Business/Technical Changes, Audit Findings, Incidents, Remediation Activities, Regulatory Changes.) 3. Communicate. What Works! • • • • People manage risk ALL THE TIME. Companies manage risks ALL THE TIME. It should feel natural, logical, And, Risk Management should ALWAYS pass the “Common Sense” test. Risk Assessment for a Presentation to ISACA I didn’t want to… • Look like an idiot. • Go over/under time too much. Questions? mchapman @ phishline.com 262.546.1867 ext. 7010 Thank You! mchapman @ phishline.com 262.546.1867 ext. 7010